NL-05-1487, Request to Revise Technical Specification Increased Flexibility in Mode Restraints Auxiliary Feedwater (AFW) System
| ML053530153 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/16/2005 |
| From: | Grissette D Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-05-1487 | |
| Download: ML053530153 (14) | |
Text
Don E. Grissette Southern Nuclear Vice President Operating Company, Inc.
40 lnverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.6474 Fax 205.992.0341 December 16, 2005 COMPANY Energy to Serve YourWorkf' Docket Nos.: 50-424 50-425 U. S. Nuclear Regulatory Commission A m : Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Request to Revise Technical Specifications Increased Flexibility in Mode Restraints Auxiliarv Feedwater (AFW) System Ladies and Gentlemen:
In accordance with the requirements of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to revise the Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2 Technical Specifications (TS). The proposed change would revise the ACTIONS NOTE for TS 3.7.5, "Auxiliary Feedwater (AFW)System." The ACTIONS NOTE was inadvertently applied incorrectly during the original submittal for TSTF-359, Revision 9, "Increased Flexibility in Mode Restraints," (NL-04-0548) on October 26, 2004. The availability of this TS improvement was announced in the Federal Register on April 4,2003 (68 FR 16579) as part of the Consolidated Line Item Improvement Process (CLIP).
The proposed change and the basis are described in Enclosure 1. The significant hazards evaluation and environmental assessment are in Enclosure 2. Marked-up TS and Bases pages are provided in Enclosure 3 and clean-typed pages are provided in Enclosure 4.
SNC requests approval of the proposed change by December 2006, with the amendment being implemented within 90 days.
(Affirmation and signature provided on following page.)
U. S. Nuclear Regulatory Commission NL 1487 Page 2 Mr. D. E. Grissette states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.
This letter contains no NRC commitments. If you have any questions, please advise.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Don E. Grissette Sworn to and subscribed before me this /d 4kday of -, 2005. : Basis for Proposed Change : 10 CFR 50.92 Significant Hazards Evaluation and Environmental Assessment : Marked-up TS and Bases Pages : Clean-typed TS and Bases Pages cc: ;
Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, General Manager - Plant Vogtle RType: CVC7000 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Vogtle Mr. G. J. McCoy, Senior Resident Inspector - Vogtle State of Georgia Mr. L. C. Barrett, Commissioner - Department of Natural Resources
Enclosure 1 Vogtle Electric Generating Plant Request to Revise Technical Specifications Increased Flexibility in Mode Restraints Auxiliary Feedwater (AFW) System Basis for Proposed Change
Enclosure 1 Vogtle Electric Generating Plant Request to Revise Technical Specifications Increased Flexibility in Mode Restraints Auxiliary Feedwater (AFW Svstem Basis for Proposed Chan~e DESCRIPTION The proposed amendment would modify the ACTIONS NOTE for Technical Specifications (TS) 3.7.5, "Auxiliary Feedwater (AFW) System." The ACTIONS NOTE in LC0 3.7.5 states that LC0 3.0.4b is not applicable when entering MODE 1. However, this is only applicable to plants that do not use AFW for startup. During the preparation of the original submittal for TSTF-359, this note was inadvertently applied incorrectly.
Since Vogtle uses AFW for startup, the note should be revised to state that LC0 3.0.4b is not applicable.
PROPOSED CHANGE Southern Nuclear Operating Company (SNC) proposes to revise the Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2 Technical Specifications (TS). The proposed change would revise the ACTIONS NOTE for TS 3.7.5, "Auxiliary Feedwater (AFW)
System." The proposed change is based on IndustrymSTF Standard Technical Specification Change Traveler TSTF-359, Revision 9, "Increased Flexibility in Mode Restraints." The following is a description of the proposed change.
TS 3.7.5, "Auxiliary Feedwater System," the ACTIONS NOTE is revised to state "LC0 3.0.4b is not applicable."
BACKGROUND TSTF-359, Revision 9 approved a revision to LC0 3.0.4 to allow entry into a MODE or other specified condition in the Applicability (MOSCA) while relying on the associated ACTIONS, provided that (a) the ACTIONS to be entered permit continued operation in the MOSCA for an unlimited period of time, or (b) there is a risk assessment performed which justifies the use of LC0 3.0.4 for a MOSCA change, or (c) an NRC-approved allowance is provided in the Specification to be entered. By letter dated October 26, 2004, Southern Nuclear Operating Company proposed license amendments to change the Technical Specifications (TS) for the Vogtle Electric Generating Plant (VEGP), Units 1 and 2. Amendments 137 and 116 approved the modification of the TS requirements to adopt the provisions of TSTF-359.
One of the risk significant systems that were excluded from the provision of LC0 3.0.4b is the AFW system. During the preparation of the original submittal, a NOTE was added to LC0 3.7.5 which states LC0 3.0.4b is not applicable when entering MODE 1.
However, this note is only applicable to plants that do not use AFW for startup. Since VEGP uses AFW for startup, the NOTE should have stated LC0 3.0.4b is not applicable.
Rather than allow use of LC0 3.0.4b for entry into MODE 3 from MODE 4 or MODE 2 from MODE 3, the correct NOTE should preclude use of LC0 3.0.4b. Therefore, TSTF-359 was incorrectly applied to the NOTE for LC0 3.7.5. Prior to the implementation of
Enclosure 1 Vogtle Electric Generating Plant Request to Revise Technical Specifications Increased Flexibility in Mode Restraints A u x i l i a ~Feedwater (AFW) System Basis for Provosed Change this license amendment, this error was discovered. Currently, there are administrative controls which will prohibit inappropriate MODE changes for LC0 3.7.5, Auxiliary Feedwater System. The implementation procedures for the AFW system are correct and prohibit the use of LC0 3.0.4b for LC0 3.7.5.
TECHNICAL ANALYSES Amendment 1371116 approved changes for TS requirements for mode change limitations in LC0 3.0.4 and Surveillance Requirement (SR) 3.0.4 to adopt provisions of IndustryRS Task Force (TSTF) change TSTF-359, "Increased Flexibility in Mode Restraints." The availability of TSTF-359 for adoption by licensees was announced in the Federal Register on April 4,2003 (68 FR 16579) as part of the Consolidated Line Item Improvement Process (CLIP).
The LC0 3.0.4b allowances apply to systems and components, and require a risk assessment prior to use to ensure an acceptable level of safety is maintained. The Auxiliary Feedwater system is one of the risk significant systems that is excluded from the new LC0 3.0.4b. Therefore, a NOTE was added to LC0 3.7.5 which states LC0 3.0.4b is not applicable for entry into MODE 1. However, this NOTE is only applicable to plants that do not use AFW for startup. Therefore, during the initial preparation of the TSTF-359 submittal, the reviewer's note of TSTF-359 for LC0 3.7.5 was not appropriately implemented. This led to an incorrect application of TSTF-359 for LC0 3.7.5. Since VEGP uses AFW for startup, the NOTE should have stated LC0 3.0.4b is not applicable. This correct NOTE would preclude use of LC0 3.0.4b for the Auxiliary Feedwater System, LC0 3.7.5. This is consistent with Attachment 4, WOG Qualitative Risk Assessment Supporting Increased Flexibility in MODE Restraints, of TSTF-359 Revision 9.
This error was discovered prior to the implementation of Amendments 1371116.
Therefore, VEGP has implemented guidelines which correctly implement the reviewer's note in TSTF-359 for LC0 3.7.5. These administrative controls prohibit inappropriate MODE changes while in LC0 3.7.5 and ensure the correct application of LC0 3.0.4b for the Auxiliary Feedwater System.
Enclosure 2 Vogtle Electric Generating Plant Request to Revise Technical Specifications Increased Flexibility in Mode Restraints Auxiliary Feedwater ( A m ) System 10 CFR 50.92 Significant Hazards Evaluation and Environmental Assessment
Enclosure 2 Vogtle Electric Generating Plant Request to Revise Technical Specifications Increased Flexibility in Mode Restraints Auxiliarv Feedwater (AFW) System 10 CFR 50.92 SIGNIFICANT HAZARDS EVALUATION AND ENVIRONMENTAL ASSESSMENT Southern Nuclear Operating Company (SNC) proposes to revise the Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2 Technical Specifications (TS). The proposed amendment would modify Technical Specification (TS) Limiting Condition for Operation (LCO) 3.7.5. The proposed amendment will correct the ACTIONS NOTE in LC0 3.7.5.
The following is a description of the proposed change.
.LC0 3.7.5, "Auxiliary Feedwater (AFW)System," the ACTIONS NOTE is revised to state LC0 3.0.4b is not applicable.
Evaluation I. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
No. The proposed change does not adversely affect accident initiators or precursors nor alter the design assumptions, conditions, or configuration of the facility or the manner in which the plant is operated and maintained. The proposed change does not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed change does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated.
Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupationaUpublic radiation exposures. The proposed change is consistent with safety analysis assumptions and resultant consequences.
Therefore, the proposed change does not increase the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?
No. The proposed change does not involve a physical alteration of the plant (i.e.,
no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new or different requirements or eliminate any existing requirements. The change does not alter assumptions made in the safety analysis. The proposed change is consistent with the safety analysis assumptions and current plant operating practice.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
Enclosure 2 Vogtle Electric Generating Plant Request to Revise Technical Specifications Increased Flexibility in Mode Restraints Auxiliary Feedwater (AFW Svstem 10 CFR 50.92 SIGNIFICANT HAZARDS EVALUATION AND ENVIRONMENTAL ASSESSMENT
- 3. Does the proposed change involve a significant reduction in a margin of safety?
No. The proposed change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined. The safety analysis acceptance criteria are not impacted by this change. The proposed change will not result in plant operation in a configuration outside the design basis.
Therefore, the proposed change does not involve a significant reduction in the margin of safety.
Conclusion Based on the preceding evaluation, Southern Nuclear has determined that the proposed change meets the requirements of 10 CFR 50.92(c) and does not involve a significant hazards consideration.
Environmental Assessment Southern Nuclear has evaluated the proposed change and determined the change does not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) a significant increase in the individual or cumulative occupational exposure. Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(~)(9),and an environmental assessment of the proposed change is not required.
Enclosure 3 Vogtle Electric Generating Plant Request to Revise Technical Specifications Increased Flexibility in Mode Restraints Auxiliary Feedwater (AFW) System Marked-up TS and Bases Pages
AM! System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LC0 3.7.5 Three AFW trains shell be OPERABLE.
APPLICABILITY: MODES 1,2. and 3.
ACTIONS
- ----- NOTE--- -
LCO 3.0.a is not applil-. -I (
CONDITION REQUIRED ACTION COMPLETION 'I'IME A. One steam swply to A.l Restore steam supply to 7 days turblne drhren AFW OPERABLE status.
pump inoperable. AN2 10 days from discovery of failure to meet the LC0 B. One AFW train B.l Restore AFW Wain to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable for reasons OPERABLE statue.
other than Condition A. AND 10 days from disoovery of failure to meet the LC0 Vogtle U n b 1 and 2 Amendment No. 137 (Unit 1)
Amendment No. 116 (Unit 2)
A m System B 3.7.5 BASES APPLICABILITY In MODE 5 or 6, the steam generators are not normally used for (continued) heat removal, and the AFW System is not required.
ACTIONS A Note prohlbits the applicatkn of LC0 3.0.4b to an inoperable
. There is an increased risk AFW trai associatedv- an AFW train inoperable and the provisions of LC0 3.0.4b, whlch aliow entry Into a MODE I
or other specified condltlon In the Applkabiiity with the LC0 not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this clrcumstance.
If one of the two steam supplies to the turbine driven AFW train is inoperable, action must be taken to restore OPERABLE status within 7 days. The 7 day Completion Time Is reasonable, based on the following reasons:
- c. The low probability of an event occurring that requires the inoperable steam supply to the turbine driven A m pump.
The second Completion Time for Required Action A.l establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.
The 10 day Completion Tlme provides a limitation time allowed in this specifled Condltlon after discovery of fallure to meet the LCO.
This limit Is considered reasonable for situations In whlch Conditions A and B are entered concurrently. The connector between 7 days and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.
With one of the requlred A m trains (pump or flow path) inoperable for reasons other than Condition A, actlon must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This (continued)
Vogtle Unlts 1 and 2 B 3.7.5.5 -
Rev. 3 8/05
Enclosure 4 Vogtle Electric Generating Plant Request to Revise Technical Specifications Increased Flexibility in Mode Restraints Auxiliary Feedwater ( A M ) System Clean-typed TS and Bases Pages
3.7 P W T SYSrEMS 3.7.5 Auxiliary Feedwater (AFW) System LC0 3.7.5 Three AFW trains shall be OPERABLE.
APPLICABIUTY: MODES 1,2. and 3.
ACTIONS NOTE LCO 3.0.4b is not applicable.
I CONDlTlON REQUIREDACTION COMPLETION TIME A One steam supply to A. 1 Reetore stem supply to 7 days turbine drhm AFW OPERABLE status.
pump inoperable. a 10 day3 frun discomy of failure to mettheLC0
- 8. One AFW train B.1 Restom AFW traln to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperablefor mesons OPERABLE status.
ather than Condition A. &!a 10 days frun discovery d failure to meet the LC0 (continued)
Vogtk Units 1and 2 Amendment No. (Unit I )
Amendment No. (Unit 2)
AFW SMem B 3.7.5 BASES APPLICABILITY In MODE 5 or 6. the steam generators are not normally used for (continued) heat removal, and the AFW System is not required.
ACTIONS A Note prohibits the applicationof LC0 3.0.4b to an Inoperable AFW train. There is an increased risk assodated with an AFW I traln inoperable and the provlslons of LC0 3.0.4b. which albw entry Into a MODE or other spedfled oondltkn In the Applicability with the LC0 not met after performance of a risk assessment addressing inoperable systems and components, should not be applled in this circumstance.
If one of the two stmm supplies to the turbine driven AFW train is Inoperable, adion must be taken to restore OPERABLE status withln 7 days. The 7 day Completion Time Is reasonable, based on the following reasons:
- c. The low probablltty of an event occurring that requires the inoperable steam supply to the turbine driven AFW pump.
The second Completion l m e for Required Action A.l establ1,shes a limit on the maximum time allowed for any comblnatbn of Condltlons to be Inoperable during any contlnwus failure to meet this LCO.
The 10 day Completlon Time provides a limitation time alkwed in this specified Conditlon after discovery of failure to meet the LCO.
This limn is comidered reasonable for situations In which Conditlons A and B are entered concurrently. The a oonnedor between 7 days and 10 days dictetea that both Completbn Times apply slmultan~usly,and the more restdctive must be met.
With one of the required AFW tralns (pump or flow path) inoperable for reasons other than Conditlon A, actlon must be taken to restore OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This (continued)
Vogtle U n b 1 and 2 B 3.7.55