View source for TSTF-07-05, TSTF-412, Revision 3, Provide Actions for One Steam Supply to Turbine Driven Afw/Efw Pump Inoperable.

{{Adams
| number = ML070100363
| issue date = 01/10/2007
| title = TSTF-412, Revision 3, Provide Actions for One Steam Supply to Turbine Driven Afw/Efw Pump Inoperable.
| author name = Crowthers M, Infanger P, Sparkman W, Woods B
| author affiliation = BWR Owners Group, PWR Owners Group, Technical Specifications Task Force
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = PROJ0753
| license number = 
| contact person = 
| case reference number = TSTF-07-05, TSTF-412, Rev 3
| document type = Letter type:TSTF
| page count = 37
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:TECHNICAL SPECIFICATIONS TASK FORCE TSTF                                           A JOINT OWNERS GROUP ACTIVITY January 10, 2007                                                                      TSTF-07-05 PROJ0753 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

==SUBJECT:==
TSTF-412, Revision 3, "Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable"

==Dear Sir or Madam:==

Enclosed for NRC review is Revision 3 of TSTF-412, "Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable." TSTF-412 is revised to address comments made by the NRC in an October 19, 2006 teleconference between the NRC and the TSTF. A description of the changes is found in the section entitled, "TSTF Revision 3, Revision Description."
Any NRC review fees associated with the review of TSTF-412 should be billed to the Pressurized Water Reactor Owners Group.
The TSTF requests that the Traveler be made available under the Consolidated Line Item Improvement Process.
Should you have any questions, please do not hesitate to contact us.
Wesley Sparkman (PWROG/W)                              Michael Crowthers (BWROG)
Brian Woods (PWROG/CE)                                 Paul Infanger (PWROG/B&W)
Enclosure cc:      Tim Kobetz, Technical Specifications Branch, NRC Ross Telson, Technical Specifications Branch, NRC 11921 Rockville Pike, Suite 100, Rockville, MD 20852 Phone: 301-984-4400, Fax: 301-984-7600 Email: tstf@excelservices.com Administered by EXCEL Services Corporation

WOG-143, Rev. 3                    TSTF-412, Rev. 3 Technical Specification Task Force Improved Standard Technical Specifications Change Traveler Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable NUREGs Affected:               1430           1431             1432            1433       1434 Classification: 1) Technical Change                                                 Recommended for CLIIP?: Yes Correction or Improvement:            Improvement                                         NRC Fee Status:           Not Exempt Benefit:       Provides Longer Completion Time Industry

==Contact:==
Wes Sparkman, (205) 992-5061, wasparkm@southernco.com

==1.0 DESCRIPTION==

This change is proposed to clarify the OPERABILITY of the turbine driven AFW pump with one steam supply inoperable.
The Bases for LCO 3.7.5 state in part: "The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each of [two] main steam lines upstream of the MSIVs, ...." LCO 3.0.2 states:
 "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated."
The existing LCO specifies the OPERABILITY of the AFW system at the train level, and the Bases state that the turbine driven AFW pump is required to be OPERABLE with redundant steam supplies. Therefore, based on LCO 3.0.2 and associated Bases, entering Condition A implies that the LCO is not met (i.e., an inoperable steam supply means that the turbine driven AFW train is inoperable).
Based on the above logic, with one steam supply inoperable, Condition A would be entered for an inoperable steam supply. Assuming that one motor driven AFW pump were declared inoperable (at the same time a steam supply was inoperable), Condition B would be entered for an inoperable motor driven AFW train as well as entry into Condition C for two inoperable AFW trains. However, the turbine driven AFW train may remain capable of performing its specified function, but with a lack of redundancy with respect to its steam supplies.
However, for some plant designs there are scenarios in which the combination of an inoperable motor driven AFW train and the turbine driven AFW train inoperable due to an inoperable steam supply can lead to less than 100% AFW flow to the SGs. Consider, for example, a four loop plant where the steam supplies for the turbine driven AFW train come from two of the SGs. The turbine driven train feeds all four SGs, and each motor driven train feeds two SGs. If one steam supply is inoperable, and the SG with the remaining steam supply becomes faulted due to a Feedline Break (FLB) or Main Steamline Break (MSLB) (whichever is limiting from the standpoint of AFW flow requirements and assuming no single failures), the turbine driven AFW train may not be able to perform its function. If the motor driven AFW train that feeds the two intact SGs is also inoperable, the remaining motor driven AFW train will be feeding only one intact SG. This may not meet safety analysis requirements. Similar scenarios are possible for three loop plants that require two motor driven AFW trains to mitigate a FLB or MSLB. For plants with this design, a Completion Time of 24 hours is proposed for new Required Actions C.1 and C.2.
For the case where a plant design still provides for 100% of the AFW flow required by the safety analysis for the FLB or the MSLB, assuming no additional single failure, with one motor driven AFW train inoperable and the turbine driven AFW train inoperable due to one steam supply inoperable, a Completion Time of 48 hours is proposed for new Required Actions C.1 and C.2.
08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-143, Rev. 3                    TSTF-412, Rev. 3

==2.0 PROPOSED CHANGE==

The following changes are proposed to STS 3.7.5, "Auxiliary Feedwater (AFW) System" (for NUREG-1431 and NUREG-1432) and STS 3.7.5, "Emergency Feedwater (EFW) System" (for NUREG-1430):
: 1.      Condition A is modified to state: "Turbine driven AFW train inoperable due to one inoperable steam supply."
: 2.      A new Condition C is added for the turbine driven AFW train inoperable due to one inoperable steam supply and one motor driven AFW pump train inoperable. For new Condition C, Required Action C.1 requires restoration of the affected steam supply to OPERABLE status in 24 hours for plants that can no longer meet the safety analysis flow to the SGs assuming no single active failure and a feedwater line break (FLB) or main steamline break (MSLB) or 48 hours for plants that can still meet the safety analysis requirements. New Required Action C.2 is also provided that addresses restoration of the inoperable motor driven AFW train within 24 or 48 hours as explained above for Required Action C.1. A Reviewers Note is added to the Condition C Bases to explain the applicability of the two bracketed Completion Times for Required Actions C.1 and C.2. Associated Bases changes are provided to support the addition of new Condition C.
: 3.      The existing Condition C is revised to Condition D, and existing Condition C is revised to address the new Condition C. The associated Bases are revised.
: 4.      Existing Condition D becomes Condition E. The associated Bases are revised.
: 5.      The Bases of NUREG-1430 are revised to replace some inaccurate references to "AFW" with "EFW."

==3.0 BACKGROUND==

The Auxiliary Feedwater (AFW) System (For B&W Plants, Emergency Feedwater (EFW) System) automatically supplies feedwater to the steam generators to remove decay heat from the Reactor Coolant System upon the loss of normal feedwater supply. The AFW pumps take suction through separate and independent suction lines from the condensate storage tank (CST) and pump to the steam generator secondary side via separate and independent connections to the main feedwater (MFW) piping outside containment. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) or atmospheric dump valves. If the main condenser is available, steam may be released via the steam bypass valves and recirculated to the CST.
For a typical Westinghouse NSSS four loop plant, the AFW System consists of two motor driven AFW pumps and one steam turbine driven pump configured into [three] trains. Each motor driven pump provides 100% of AFW flow capacity, and the turbine driven pump provides 200% of the required capacity to the steam generators, as assumed in the accident analysis. The pumps are equipped with independent recirculation lines to prevent pump operation against a closed system. Each motor driven AFW pump is powered from an independent Class 1E power supply and feeds [two] steam generators (SGs), although each pump has the capability to be realigned to feed other SGs. The steam turbine driven AFW pump receives steam from two main steam lines upstream of the main steam isolation valves. Each of the steam feed lines will supply 100%
of the requirements of the turbine driven AFW pump. The steam turbine driven AFW pump feeds all of the SGs.
The AFW System is capable of supplying feedwater to the steam generators during normal unit startup, shutdown, and hot standby conditions.
08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-143, Rev. 3                    TSTF-412, Rev. 3

==4.0 TECHNICAL ANALYSIS==

A turbine driven AFW pump with a single OPERABLE steam supply is capable of performing its safety function in the absence of a single failure. The ITS ACTIONS in many specifications recognize that loss of single failure protection in a subsystem is a less degraded condition than inoperability and provide longer Completion Times for those situations.
Condition A is modified to indicate that the turbine driven AFW train is inoperable due to one steam supply inoperable. With one steam supply inoperable, the turbine driven AFW train is considered inoperable but is still capable of performing its specified function. A new Condition C is proposed that will require restoring an AFW train to OPERABLE status in 24 hours if one motor driven AFW train is inoperable and the turbine driven AFW train is inoperable due to one steam supply inoperable. This Completion Time is applicable when the condition could result in the inability of the AFW system to provide 100% of the flow required by the safety analysis for the FLB or the MSLB, whichever is most limiting, assuming no additional single failure. This Completion Time is reasonable based on the remaining OPERABLE motor driven AFW train, the remaining OPERABLE steam supply to the turbine driven AFW pump, the turbine driven AFW pump still being capable of performing its specified function, and the low probability of an event that would result in the inability of the AFW system to provide 100% of the required flow. A 48 hour Completion Time is proposed for this condition when plant design still provides for 100% of the AFW flow requirements regardless of this scenario. This Completion Time is reasonable since the consequences of this configuration are less severe, but the configuration represents a higher level of degradation than one inoperable AFW train, which can exist for 72 hours per Condition B.
The proposed new Condition C addresses the ability of the AFW system to mitigate the most limiting design basis events (e.g., a FLB or MSLB), excluding a single failure, with one inoperable steam supply to the turbine driven train and an inoperable motor driven train. For example, a typical Westinghouse three-loop design feeds all three steam generators with two motor driven AFW trains and a turbine driven train. The turbine driven AFW steam supplies are taken from two of the steam generators. If the turbine driven AFW train is inoperable due to one steam supply inoperable and a motor driven AFW train is inoperable, and the steam generator with the remaining steam supply is faulted, the remaining motor driven train will be able to feed two intact steam generators. Therefore, the design basis may be met, and the Completion Time of 48 hours is appropriate. However, if due to plant design, there are scenarios where 2 out of 3 AFW trains are required for a three loop plant, the more limiting Completion Time of new Condition C (24 hours) is appropriate. For the two loop design, there must be a remaining motor driven train capable of feeding the remaining intact steam generator.
In a typical four-loop design, each motor driven AFW train feeds two steam generators, and the turbine driven train feeds all four steam generators. As with the three-loop design, the success criteria for the AFW system require that two intact steam generators receive AFW flow. The new Condition's Completion Time for an inoperable turbine driven AFW train due to one steam supply inoperable and an inoperable motor driven AFW train is based on whether the success criteria can be met. Consequently, a Reviewers Note is applied to the new Condition to distinguish between those designs which can meet the design basis for all scenarios, and those which cannot.
08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-143, Rev. 3                    TSTF-412, Rev. 3

==5.0 REGULATORY ANALYSIS==

5.1 NO SIGNIFICANT HAZARDS CONSIDERATION The TSTF has evaluated whether or not a significant hazards consideration is involved with the proposed generic change by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
Standard I -         Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated The proposed changes clarify the operability requirements of the Auxiliary Feedwater (AFW) System (Emergency Feedwater (EFW) System for Babcock & Wilcox designed plants) when one steam supply to the turbine-driven AFW or EFW pump is unavailable. The AFW or EFW System is not an initiator of any design basis accident or event, and therefore the proposed changes do not increase the probability of any accident previously evaluated. The AFW or EFW system is used to respond to accidents previously evaluated. The proposed change affects only the actions taken when portions of the AFW or EFW system are unavailable and does not affect the design of the AFW or EFW System. The proposed Condition does not significantly change how the plant would mitigate an accident previously evaluated.
Therefore, it is concluded that the proposed change does not result in a significant increase in the probability or consequences of an accident previously evaluated.
Standard II -             Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated The proposed changes do not result in a change in the manner in which the AFW System provides plant protection. The AFW System will continue to supply water to the steam generators to remove decay heat and other residual heat by delivering at least the minimum required flow rate to the steam generators. There are no design changes associated with the proposed changes. The changes to the Conditions and Required Actions do not change any existing accident scenarios, nor create any new or different accident scenarios.
The changes do 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 changes do not impose any new or different requirements or eliminate any existing requirements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.
Therefore, it is concluded that the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Standard III - Involve a Significant Reduction in a Margin of Safety The proposed changes do 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 these changes. The proposed changes will not result in plant operation in a configuration outside the design basis.
Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.
08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-143, Rev. 3                    TSTF-412, Rev. 3 5.2 Applicable Regulatory Requirements/Criteria The proposed change does not affect the regulatory requirements for the AFW system. Therefore, based on the considerations discussed above, (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 Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

==6.0 ENVIRONMENTAL CONSIDERATION==

A review has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

==7.0 REFERENCES==

None.
Revision History OG Revision 0                                  Revision Status: Closed Revision Proposed by: WOG Revision

== Description:==

Original Issue Owners Group Review Information Date Originated by OG: 13-Aug-99 Owners Group Comments (No Comments)
Owners Group Resolution:            Superceeded Date:
OG Revision 1                                  Revision Status: Closed Revision Proposed by: WOG Revision

== Description:==

Proposed Condition E is modified to contain a Note, similar to the Note in Condition F, which suspends requirements to change MODES until an AFW train is restored to OPERABLE status.
Owners Group Review Information Date Originated by OG: 08-Dec-99 Owners Group Comments (No Comments)
Owners Group Resolution:            Superceeded Date: 08-Dec-99 08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-143, Rev. 3                   TSTF-412, Rev. 3 OG Revision 2                                  Revision Status: Closed Revision Proposed by: WOG Revision

== Description:==

Reworded Condition A to "Turbine driven AFW train inoperable due to one inoperable steam supply OR, etc." New Conditions C and E are be reworded in the same fashion. Clarification was made in the Bases that the turbine driven train remains capable of performing its specified function, but it is considered inoperable because of the lack of redundant steam supplies to the pump. This is consistent with the statements in the other Conditions regarding an AFW train inoperable for reasons than Condition A.
Owners Group Review Information Date Originated by OG: 29-Nov-00 Owners Group Comments WOG approved with editorial corrections to the justification.
Owners Group Resolution:            Approved          Date: 08-Mar-01 TSTF Review Information TSTF Received Date:          06-Apr-01                  Date Distributed for Review 06-Apr-01 OG Review Completed:               BWOG            WOG            CEOG          BWROG TSTF Comments:
5/2/01 - CEOG recommends reconsidering need for the new Condition E. Recommend that the new Condition be deleted and that for this situation the three AFW trains inoperable Condition be entered.
TSTF Resolution:         Superceeded                                         Date: 02-May-01 OG Revision 3                                  Revision Status: Closed Revision Proposed by: WOG Revision

== Description:==

Eliminated proposed Condition E.
Owners Group Review Information Date Originated by OG: 03-May-01 Owners Group Comments (No Comments)
Owners Group Resolution:            Approved          Date: 03-May-01 TSTF Review Information TSTF Received Date:          25-May-01                  Date Distributed for Review 10-Jun-01 OG Review Completed:               BWOG            WOG            CEOG          BWROG TSTF Comments:
Approved on 5/2/01 pending resolution of need for Condition E.
6/10/2001 - Change prepared. Need CEOG and BWOG prioritization information.
08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-143, Rev. 3                   TSTF-412, Rev. 3 OG Revision 3                                  Revision Status: Closed TSTF Resolution:         Approved                                            Date: 25-May-01 NRC Review Information NRC Received Date:            27-Jun-01 NRC Comments:                                                                       Date of NRC Letter: 12-Jul-02 7/1/2002 - E-mail from Steve Wideman: On July 1, 2002, I had a telecon with Craig Harbuck (TS Section) and Jim Tatum (Plant System Branch) regarding TSTF-412, "Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable," at their request. Jim Tatum essentially indicated that some change to the STS was needed but was questioning the proposed new Condition for one MD AFW/EFW train inoperable AND one TD AFW/EFW train inoperable due to one inoperable steam supply as to whether it was appropriate to all the different plant designs. Jim also indicated that if the AFW/EFW design basis can be met then a 72 hour Completion Time (as opposed to 24 hours would be appropriate). Jim kept referring to an amendment (No. 173 for Waterford) and what was done for Waterford. I did not commit to make any changes but agree to review the Waterford submittal and amendment. Additionally, Jim and Craig indicated that they would develop some specific comments and provide those comments to the NEI TSTF.
7/12/02 - NRC provided letter with comments.
Final Resolution:        NRC Requests Changes: TSTF Considering                     Final Resolution Date:           12-Jul-02 TSTF Revision 1                                Revision Status: Closed Revision Proposed by: WOG Revision

== Description:==

Revised to address the comments in the NRC's 7/12/02 letter. The letter is attached and is annotated to indicate that the NRC's suggested changes were adopted.
Condition C is revised to address the condition of one turbine-driven AFW train inoperable due to one inoperable steam supply and one motor driven AFW train inoperable. For new Condition C, Required Action C.1 requires restoration of the affected steam supply to OPERABLE status in 24 hours for plants that can no longer meet the safety analysis flow to the SGs assuming no single active failure and a feedwater line break (FLB) or main steamline break (MSLB) or 48 hours for plants that can still meet the safety analysis requirements. New Required Action C.2 is also provided that addresses restoration of the inoperable motor driven AFW train within 24 or 48 hours as explained above for Required Action C.1. A Reviewers Note is added to the Bases explain the applicability of the two bracketed Completion Times for Required Actions C.1 and C.2.
The existing Condition C is revised to Condition D, and existing Condition C is revised to address the case where three trains of AFW are inoperable due to the turbine driven AFW train being inoperable solely due to one inoperable steam supply.
Existing Condition D becomes Condition E and is revised to address two motor driven AFW trains inoperable and turbine driven AFW train inoperable for reasons other than one inoperable steam supply. The existing Condition E is revised to Condition F.
08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-143, Rev. 3                   TSTF-412, Rev. 3 TSTF Revision 1                                Revision Status: Closed Owners Group Review Information Date Originated by OG: 08-Dec-04 Owners Group Comments (No Comments)
Owners Group Resolution:            Approved          Date: 08-Dec-04 TSTF Review Information TSTF Received Date:          19-Jan-05                  Date Distributed for Review 19-Jan-05 OG Review Completed:               BWOG            WOG            CEOG          BWROG TSTF Comments:
(No Comments)
TSTF Resolution:         Approved                                            Date: 25-Jan-05 NRC Review Information NRC Received Date:            31-Jan-05 Final Resolution:        Superceded by Revision TSTF Revision 2                                Revision Status: Closed Revision Proposed by: WOG Revision

== Description:==

Revised the Bases to address NRC comments. Changed the Required Action A.1 Bases, paragraph a, to state that the proposed Completion Time is appropriate because the turbine driven train is still capable of performing its specified function for most postulated events. Eliminated the repeated phrase "turbine driven" from the Required Action E.1 Bases.
Owners Group Review Information Date Originated by OG: 08-Dec-05 Owners Group Comments (No Comments)
Owners Group Resolution:            Approved          Date: 02-Jan-06 TSTF Review Information TSTF Received Date:          02-Jan-06                  Date Distributed for Review 02-Jan-06 OG Review Completed:               BWOG            WOG            CEOG          BWROG TSTF Comments:
08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-143, Rev. 3                   TSTF-412, Rev. 3 TSTF Revision 2                                Revision Status: Closed (No Comments)
TSTF Resolution:         Approved                                            Date: 31-Jan-06 NRC Review Information NRC Received Date:            31-Jan-06 NRC Comments:
On a teleconference held on October 19, 2006 between the NRC and the TSTF, the NRC requested that the Traveler be revised to remove the changes to TSTF-412 that require a plant shutdown when the only available AFW/EFW pump is a turbine driven pump with one available steam supply. The TSTF agreed.
Final Resolution:        Superceded by Revision TSTF Revision 3                                Revision Status: Active Revision Proposed by: NRC Revision

== Description:==

On a teleconference held on October 19, 2006 between the NRC and the TSTF, the NRC requested that the Traveler be revised to remove the changes to TSTF-412 that require a plant shutdown when the only available AFW/EFW pump is a turbine driven pump with one available steam supply. The TSTF agreed. The changes to Conditions D and E and their associated Bases are removed and the justification is revised to reflect these changes.
TSTF Review Information TSTF Received Date:          06-Nov-06                  Date Distributed for Review 06-Nov-06 OG Review Completed:               BWOG            WOG            CEOG          BWROG TSTF Comments:
(No Comments)
TSTF Resolution:         Approved                                            Date: 04-Jan-07 NRC Review Information NRC Received Date:            10-Jan-07 Affected Technical Specifications Action 3.7.5.A              EFW Systems                                                          NUREG(s)- 1430 Only Action 3.7.5.A Bases        EFW Systems                                                          NUREG(s)- 1430 Only 08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

WOG-143, Rev. 3                    TSTF-412, Rev. 3 Action 3.7.5.C              EFW Systems                                                         NUREG(s)- 1430 Only Change

== Description:==
New Action Action 3.7.5.C              EFW Systems                                                         NUREG(s)- 1430 Only Change

== Description:==
Renamed to D and modified Action 3.7.5.C Bases        EFW Systems                                                         NUREG(s)- 1430 Only Change

== Description:==
New Action Action 3.7.5.C Bases        EFW Systems                                                         NUREG(s)- 1430 Only Change

== Description:==
Renamed to D and modified Action 3.7.5.D              EFW Systems                                                         NUREG(s)- 1430 Only Change

== Description:==
Renamed to E.
Action 3.7.5.D Bases        EFW Systems                                                         NUREG(s)- 1430 Only Change

== Description:==
Renamed to E.
Action 3.7.5.E              EFW Systems                                                         NUREG(s)- 1430 Only Change

== Description:==
Renamed to F Action 3.7.5.E Bases        EFW Systems                                                         NUREG(s)- 1430 Only Change

== Description:==
Renamed to F Action 3.7.5.A              AFW Systems                                                         NUREG(s)- 1431 1432 Only Action 3.7.5.A Bases        AFW Systems                                                         NUREG(s)- 1431 1432 Only Action 3.7.5.C              AFW Systems                                                         NUREG(s)- 1431 1432 Only Change

== Description:==
New Action Action 3.7.5.C              AFW Systems                                                         NUREG(s)- 1431 1432 Only Change

== Description:==
Renamed to D and modified Action 3.7.5.C Bases        AFW Systems                                                         NUREG(s)- 1431 1432 Only Change

== Description:==
Renamed to D and modified Action 3.7.5.C Bases        AFW Systems                                                         NUREG(s)- 1431 1432 Only Change

== Description:==
New Action Action 3.7.5.D              AFW Systems                                                         NUREG(s)- 1431 1432 Only Change

== Description:==
Renamed to E.
Action 3.7.5.D Bases        AFW Systems                                                         NUREG(s)- 1431 1432 Only Change

== Description:==
Renamed to E.
Action 3.7.5.E              AFW Systems                                                         NUREG(s)- 1431 1432 Only Change

== Description:==
Renamed to F Action 3.7.5.E Bases        AFW Systems                                                         NUREG(s)- 1431 1432 Only Change

== Description:==
Renamed to F 08-Jan-07 Traveler Rev. 3. Copyright (C) 2006, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.

TSTF-412, Rev. 3 EFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5          Emergency Feedwater (EFW) System LCO 3.7.5                     [Three] EFW trains shall be OPERABLE.
                             ---------------------------------------------NOTE--------------------------------------------
Only one EFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.
APPLICABILITY:                MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.
ACTIONS
-----------------------------------------------------------NOTE-----------------------------------------------------------
LCO 3.0.4.b is not applicable when entering MODE 1.
CONDITION                                REQUIRED ACTION                            COMPLETION TIME A. [ Turbine driven EFW                   A.1        Restore affected equipment               7 days ]
train inoperable due to                         to OPERABLE status.
one inoperable steam supplyOne steam supply to turbine driven EFW pump inoperable.
OR
       ------------NOTE------------
Only applicable if MODE 2 has not been entered following refueling.
One turbine driven EFW pump inoperable in MODE 3 following refueling.
BWOG STS                                                   3.7.5-1                                     Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 EFW System 3.7.5 ACTIONS (continued)
CONDITION                  REQUIRED ACTION                        COMPLETION TIME B. One EFW train               B.1  Restore EFW train to                  72 hours inoperable in MODE 1,           OPERABLE status.
2, or 3 [for reasons other than Condition A] in MODE 1, 2, or 3.
C. One turbine driven EFW      C.1  Restore the steam supply              [24 or 48] hours train inoperable due to         to the turbine driven train to one inoperable steam            OPERABLE status.
supply.
OR AND C.2  Restore the motor driven              [24 or 48] hours Motor driven EFW train          EFW train to OPERABLE inoperable.                     status.
CD. Required Action and    CD.1 Be in MODE 3.                         6 hours associated Completion Time of Condition A [B,    AND or CB] not met.
CD.2 Be in MODE 4.                         [18] hours
[ OR Two EFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C. ]
DE. [Three] EFW trains         DE.1 --------------NOTE---------------
inoperable in MODE 1,           LCO 3.0.3 and all other 2, or 3.                        LCO Required Actions requiring MODE changes are suspended until one EFW train is restored to OPERABLE status.
Initiate action to restore            Immediately one EFW train to OPERABLE status.
EF. Required EFW train         EF.1 Initiate action to restore            Immediately BWOG STS                                 3.7.5-2                                 Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 EFW System 3.7.5 inoperable in MODE 4. EFW train to OPERABLE status.
BWOG STS                    3.7.5-3             Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 EFW System B 3.7.5 BASES ACTIONS  A Note prohibits the application of LCO 3.0.4.b to an inoperable EFW train when entering MODE 1. There is an increased risk associated with entering MODE 1 with EFW inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.
[ A.1 With one of the two steam supplies to the turbine driven EFW pump inoperable due to one inoperable steam supply, or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:
: a. For the inoperability of a steam supply to the a turbine driven EFW pump due to one inoperable steam supply, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events.
: b. For the inoperability of a turbine driven EFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.
: c. For both the inoperability of a steam supply line to the a turbine driven pump due to one inoperable steam supply and an inoperable turbine driven EFW pump while in MODE 3 immediately following refueling, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven EFW pumps, and due to the low probability of an event requiring the use of the inoperable turbine driven EFW pump.
Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turbine driven EFW pump in MODE 3 to when the unit has not entered MODE 2 following a refueling. Condition A allows one EFW train to be inoperable for 7 days vice the 72 hour Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical. ]
BWOG STS                     B 3.7.5-4                              Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 EFW System B 3.7.5 BASES ACTIONS (continued)
B.1 When one of the required EFW trains (pump or flow path) is inoperable in MODE 1, 2, or 3 [for reasons other than Condition A], action must be taken to restore the train to OPERABLE status within 72 hours. This Condition includes the loss of two steam supply lines to one of the turbine driven EFW pumps. The 72 hour Completion Time is reasonable, based on the redundant capabilities afforded by the EFW System, time needed for repairs, and the low probability of a DBA occurring during this time period.
C.1 and C.2 With the required motor driven EFW train (pump or flow path) inoperable and one of the turbine driven EFW trains inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within [24] [48] hours. Assuming no single active failures when in this condition, the accident (a FLB or MSLB) could result in the loss of the remaining steam supply to the inoperable turbine driven EFW pump due to the faulted SG. In this condition, the EFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis, [either due to the analysis requiring flow from two EFW pumps or due to the remaining EFW pump having to feed a faulted SG].
                  ------------------------------------REVIEWERS NOTE----------------------------------
Licensees should adopt the appropriate Completion Time based on their plant design. The 24 hour Completion Time is applicable to plants that can no longer meet the safety analysis requirement of 100% EFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the inoperable turbine driven EFW pump. The 48 hour Completion Time is applicable to plants that can still meet the safety analysis requirement of 100% EFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven EFW pump.
[The 24 hour Completion Time is reasonable based on the remaining OPERABLE steam supply to the affected turbine driven EFW pump, the availability of the remaining OPERABLE turbine driven EFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the affected turbine driven EFW pump]
[The 48 hour Completion Time is reasonable based on the fact that the remaining turbine driven EFW train is capable of providing 100 % of the BWOG STS                                 B 3.7.5-5                                          Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 EFW System B 3.7.5 EFW flow requirements, and the low probability of an event occurring that would challenge the EFW system.]
D.1 and D.2 When either Required Action A.1 or [, Required Action B.1, C1, or C.2]
cannot be completed within the required Completion Time, [or when two EFW trains are inoperable in MODE 1, 2, or 3, for reasons other than Condition C] the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours and in MODE 4 within [18] hours.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
In MODE 4, with two EFW trains inoperable, operation is allowed to continue because only one motor driven EFW train is required in accordance with the Note that modifies the LCO. Although not required, the unit may continue to cool down and initiate DHR.
DE.1 Required Action DE.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until at least one EFW train is restored to OPERABLE status.
With [all] EFW trains inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety grade equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore at least one EFW train to OPERABLE status.
LCO 3.0.3 is not applicable, as it could force the units into a less safe condition.
BWOG STS                   B 3.7.5-6                                Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 EFW System B 3.7.5 BASES ACTIONS (continued)
EF.1 In MODE 4, either the steam generator loops or the DHR loops can be used to provide heat removal, which is addressed in LCO 3.4.6, "RCS Loops - MODE 4." With one EFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status.
SURVEILLANCE      SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the EFW water and steam supply flow paths provides assurance that the proper flow paths exist for EFW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since those valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.
The 31 day Frequency is based on engineering judgment, is consistent with the procedural controls governing valve operation, and ensures correct valve positions.
SR 3.7.5.2 Verifying that each EFW pump's developed head at the flow test point is greater than or equal to the required developed head ensures that EFW pump performance has not degraded during the cycle. Flow and differential head are normal tests of pump performance required by the ASME Code (Ref. 3). Because it is undesirable to introduce cold EFW into the steam generators while they are operating, this test is performed on recirculation flow.
This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect incipient failures by indicating abnormal performance. Performance of inservice testing in the ASME Code (Ref. 3), at 3 month intervals, satisfies this requirement.
BWOG STS                             B 3.7.5-7                               Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 EFW System B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued)
This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.
SR 3.7.5.3 This SR verifies that EFW can be delivered to the appropriate steam generator in the event of any accident or transient that generates a Steam and Feedwater Rupture Control System (SFRCS) signal by demonstrating that each automatic valve in the flow path actuates to its correct position on an actual or simulated actuation signal. This SR is not required for valves that are locked, sealed, or otherwise secured in position under administrative controls. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. The
[18] month Frequency is also acceptable based on operating experience and design reliability of the equipment. This SR is modified by a Note that states the SR is not required to be met in MODE 4. In MODE 4, the required AFW EFW train is already aligned and operating. This SR is modified by [a] [two] Note[s]. [Note 1 indicates that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.] [The]
Note [2] states that the SR is not required to be met in MODE 4. [In MODE 4, the required pump is already operating and the autostart function is not required.] [In MODE 4, the heat removal requirements would be less providing more time for operator action to manually start the required AFW EFW pump.]
SR 3.7.5.4 This SR verifies that the turbine driven EFW pumps start in the event of any accident or transient that generates an SFRCS signal by demonstrating that each turbine driven EFW pump starts automatically on an actual or simulated actuation signal. These pumps are not required in MODE 4. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. This SR is modified by [a] [two] Note[s].
[Note 1 indicates that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam BWOG STS                            B 3.7.5-8                             Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 EFW System B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued) pressure to perform the test.] [The] Note [2] states that the SR is not required to be met in MODE 4. [In MODE 4, the required pump is already operating and the autostart function is not required.] [In MODE 4, the heat removal requirements would be less providing more time for operator action to manually start the required AFW EFW pump.]
                 -----------------------------------REVIEWERS NOTE-----------------------------------
Some plants may not routinely use the AFW EFW for heat removal in MODE 4. The second justification is provided for plants that use a startup feedwater pump rather than AFW EFW for startup and shutdown.
SR 3.7.5.5 This SR ensures that the EFW System is properly aligned by verifying the flow paths to each steam generator prior to entering MODE 2 after more than 30 days in any combination of MODE 5 or 6, or defueled.
OPERABILITY of EFW flow paths must be demonstrated before sufficient core heat is generated that would require the operation of the EFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgment, in view of other administrative controls to ensure that the flow paths are OPERABLE. To further ensure EFW System alignment, flow path OPERABILITY is verified, following extended outages to determine no misalignment of valves has occurred. This SR ensures that the flow path from the CST to the steam generator is properly aligned. (This SR is not required by those units that use EFW for normal startup and shutdown.)
[ SR 3.7.5.6 and SR 3.7.5.7 For this facility, the CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION for the EFW pump suction pressure interlocks are as follows:
A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. ]
BWOG STS                                B 3.7.5-9                                          Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5          Auxiliary Feedwater (AFW) System LCO 3.7.5                     [Three] AFW trains shall be OPERABLE.
                             ---------------------------------------------NOTE--------------------------------------------
[ Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4. ]
APPLICABILITY:                MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.
ACTIONS
------------------------------------------------------------NOTE-----------------------------------------------------------
LCO 3.0.4.b is not applicable [when entering MODE 1.]
CONDITION                                REQUIRED ACTION                            COMPLETION TIME A. [Turbine driven AFW                    A.1        Restore affected equipment               7 days ]
train inoperable due to                         to OPERABLE status.
one inoperable steam supply One steam supply to turbine driven AFW pump inoperable.
OR
       ------------NOTE------------
Only applicable if MODE 2 has not been entered following refueling.
One turbine driven AFW pump inoperable in MODE 3 following refueling.
WOG STS                                                    3.7.5-1                                     Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System 3.7.5 ACTIONS (continued)
CONDITION                  REQUIRED ACTION                        COMPLETION TIME B. One AFW train               B.1  Restore AFW train to                  72 hours inoperable in MODE 1,           OPERABLE status.
2, or 3 [for reasons other than Condition A].
C. Turbine driven AFW          C.1  Restore the steam supply              [24 or 48] hours train inoperable due to         to the turbine driven train to one inoperable steam            OPERABLE status.
supply.
OR AND C.2  Restore the motor driven              [24 or 48] hours One motor driven AFW            AFW train to OPERABLE train inoperable.               status.
CD. Required Action and    CD.1 Be in MODE 3.                         6 hours associated Completion Time for of Condition A [, AND B, or BC] not met.
CD.2 [ Be in MODE 4.                       [18] hours ]
[ OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C. ]
ED. [ Three] AFW trains        DE.1 --------------NOTE--------------
inoperable in MODE 1,           LCO 3.0.3 and all other 2, or 3.                        LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.
Initiate action to restore            Immediately ]
one AFW train to OPERABLE status.
EF. Required AFW train         EF.1 Initiate action to restore            Immediately inoperable in MODE 4.           AFW train to OPERABLE WOG STS                                  3.7.5-2                                 Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System 3.7.5 status.
WOG STS    3.7.5-3  Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 B 3.7 PLANT SYSTEMS B 3.7.5 Auxiliary Feedwater (AFW) System BASES BACKGROUND            The AFW System automatically supplies feedwater to the steam generators to remove decay heat from the Reactor Coolant System upon the loss of normal feedwater supply. The AFW pumps take suction through separate and independent suction lines from the condensate storage tank (CST) (LCO 3.7.6, "Condensate Storage Tank (CST)") and pump to the steam generator secondary side via separate and independent connections to the main feedwater (MFW) piping outside containment. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) (LCO 3.7.1, "Main Steam Safety Valves (MSSVs)") or atmospheric dump valves (LCO 3.7.4, "Atmospheric Dump Valves (ADVs)"). If the main condenser is available, steam may be released via the steam bypass valves and recirculated to the CST.
The AFW System consists of [two] motor driven AFW pumps and one steam turbine driven pump configured into [three] trains. Each motor driven pump provides [100]% of AFW flow capacity, and the turbine driven pump provides [200]% of the required capacity to the steam generators, as assumed in the accident analysis. The pumps are equipped with independent recirculation lines to prevent pump operation against a closed system. Each motor driven AFW pump is powered from an independent Class 1E power supply and feeds [two] steam generators, although each pump has the capability to be realigned from the control room to feed other steam generators. The steam turbine driven AFW pump receives steam from two main steam lines upstream of the main steam isolation valves. Each of the steam feed lines will supply 100% of the requirements of the turbine driven AFW pump.
The AFW System is capable of supplying feedwater to the steam generators during normal unit startup, shutdown, and hot standby conditions.
The turbine driven AFW pump supplies a common header capable of feeding all steam generators with DC powered control valves actuated to the appropriate steam generator by the Engineered Safety Feature Actuation System (ESFAS). One pump at full flow is sufficient to remove decay heat and cool the unit to residual heat removal (RHR) entry conditions. Thus, the requirement for diversity in motive power sources for the AFW System is met.
WOG STS                                     B 3.7.5-1                          Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 BASES BACKGROUND (continued)
The AFW System is designed to supply sufficient water to the steam generator(s) to remove decay heat with steam generator pressure at the setpoint of the MSSVs. Subsequently, the AFW System supplies sufficient water to cool the unit to RHR entry conditions, with steam released through the ADVs.
The AFW System actuates automatically on steam generator water level -
low-low by the ESFAS (LCO 3.3.2, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation"). The system also actuates on loss of offsite power, safety injection, and trip of all MFW pumps.
The AFW System is discussed in the FSAR, Section [10.4.9] (Ref. 1).
APPLICABLE      The AFW System mitigates the consequences of any event with loss of SAFETY          normal feedwater.
ANALYSES The design basis of the AFW System is to supply water to the steam generator to remove decay heat and other residual heat by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest steam generator safety valve set pressure plus 3%.
In addition, the AFW System must supply enough makeup water to replace steam generator secondary inventory lost as the unit cools to MODE 4 conditions. Sufficient AFW flow must also be available to account for flow losses such as pump recirculation and line breaks.
The limiting Design Basis Accidents (DBAs) and transients for the AFW System are as follows:
: a. Feedwater Line Break (FWLB) and
: b. Loss of MFW.
In addition, the minimum available AFW flow and system characteristics are serious considerations in the analysis of a small break loss of coolant accident (LOCA).
The AFW System design is such that it can perform its function following an FWLB between the MFW isolation valves and containment, combined with a loss of offsite power following turbine trip, and a single active failure of the steam turbine driven AFW pump. In such a case, the WOG STS                                 B 3.7.5-2                           Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 BASES APPLICABILITY In MODES 1, 2, and 3, the AFW System is required to be OPERABLE in the event that it is called upon to function when the MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace the steam generator secondary inventory, lost as the unit cools to MODE 4 conditions.
In MODE 4 the AFW System may be used for heat removal via the steam generators.
In MODE 5 or 6, the steam generators are not normally used for heat removal, and the AFW System is not required.
ACTIONS       -----------------------------------REVIEWERS NOTE-----------------------------------
The LCO 3.0.4.b Note prohibits application of the LCO 3.0.4.b exception when entering MODE 1 if the plant does not depend on AFW for startup.
If the plant does depend on AFW for startup, the Note should state, LCO 3.0.4.b is not applicable.
A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train [when entering MODE 1]. There is an increased risk associated with
[entering a MODE or other specified condition in the Applicability]
[entering MODE 1] with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.
[ A.1 If one of the two steam supplies to the turbine driven AFW train is inoperable due to one inoperable steam supply, or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:
: a. For the inoperability of a steam supply to the turbine driven AFW pump due to one inoperable steam supply, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events.
: b. For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.
WOG STS                                   B 3.7.5-4                                     Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 BASES ACTIONS (continued)
: c. For both the inoperability of a steam supply line to the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps, and due to the low probability of an event requiring the use of the turbine driven AFW pump.
Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turbine driven AFW pump in MODE 3 to when the unit has not entered MODE 2 following a refueling. Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical. ]
B.1 With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 [for reasons other than Condition A], action must be taken to restore OPERABLE status within 72 hours. This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour Completion Time is reasonable, based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA occurring during this time period.
C.1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within [24] [48] hours. Assuming no single active failures when in this condition, the accident (a FLB or MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG. In this condition, the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis, [either due to the analysis requiring flow from two AFW pumps or due to the remaining AFW pump having to feed a faulted SG].
                  ------------------------------------REVIEWERS NOTE----------------------------------
Licensees should adopt the appropriate Completion Time based on their plant design. The 24 hour Completion Time is applicable to plants that can no longer meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting WOG STS                                       B 3.7.5-5                        Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 in the loss of the remaining steam supply to the turbine driven AFW pump. The 48 hour Completion Time is applicable to plants that can still meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump.
[The 24 hour Completion Time is reasonable based on the remaining OPERABLE steam supply to the turbine driven AFW pump, the availability of the remaining OPERABLE motor driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine driven AFW pump]
[The 48 hour Completion Time is reasonable based on the fact that the remaining motor driven AFW train is capable of providing 100 % of the AFW flow requirements, and the low probability of an event occurring that would challenge the AFW system.]
D.1 and D.2 When Required Action A.1 [or ,B.1, C.1, or C.2] cannot be completed within the required Completion Time, or if two AFW trains are inoperable in MODE 1, 2, or 3 for reasons other than Condition C, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4 within [18] hours.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
In MODE 4 with two AFW trains inoperable, operation is allowed to continue because only one motor driven pump AFW train is required in accordance with the Note that modifies the LCO. Although not required, the unit may continue to cool down and initiate RHR.
WOG STS                             B 3.7.5-6                                     Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 BASES ACTIONS (continued)
DE.1 If all [three] AFW trains are inoperable in MODE 1, 2, or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status.
Required Action DE.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status. In this case, LCO 3.0.3 is not applicable because it could force the unit into a less safe condition.
EF.1 In MODE 4, either the reactor coolant pumps or the RHR loops can be used to provide forced circulation. This is addressed in LCO 3.4.6, "RCS Loops - MODE 4." With one required AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status. The immediate Completion Time is consistent with LCO 3.4.6.
SURVEILLANCE      SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the AFW System water and steam supply flow paths provides assurance that the proper flow paths will exist for AFW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since they are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.
WOG STS                                   B 3.7.5-7                           Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5          Auxiliary Feedwater (AFW) System LCO 3.7.5                     [Three] AFW trains shall be OPERABLE.
                             ---------------------------------------------NOTE--------------------------------------------
Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.
APPLICABILITY:                MODES 1, 2, and 3,
[MODE 4 when steam generator is relied upon for heat removal].
ACTIONS
-----------------------------------------------------------NOTE-----------------------------------------------------------
LCO 3.0.4.b is not applicable.
CONDITION                                REQUIRED ACTION                            COMPLETION TIME A. [ Turbine driven AFW                   A.1        Restore affected equipment               7 days ]
train inoperable due to                         to OPERABLE status.
one inoperable steam supplyOne steam supply to turbine driven AFW pump inoperable.
OR
       ------------NOTE------------
Only applicable if MODE 2 has not been entered following refueling.
One turbine driven AFW pump inoperable in MODE 3 following refueling.
CEOG STS                                                   3.7.5-1                                     Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System 3.7.5 ACTIONS (continued)
CONDITION                  REQUIRED ACTION                        COMPLETION TIME B. One AFW train               B.1  Restore AFW train to                  72 hours inoperable in MODE 1,           OPERABLE status.
2, or 3 [for reasons other than Condition A] in MODE 1, 2, or 3.
C. Turbine driven AFW          C.1  Restore the steam supply              [24 or 48] hours train inoperable due to         to the turbine driven train to one inoperable steam            OPERABLE status.
supply.
OR AND C.2  Restore the motor driven              [24 or 48] hours One motor driven AFW            AFW train to OPERABLE train inoperable.               status.
CD. Required Action and    CD.1 Be in MODE 3.                         6 hours associated Completion Time of Condition A [, B,  AND or BC] not met.
CD.2 Be in MODE 4.                         [18] hours
[ OR
[Two] AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C. ]
DE. [ [Three] AFW trains       DE.1 ---------------NOTE--------------
inoperable in MODE 1,           LCO 3.0.3 and all other 2, or 3.                        LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.
Initiate action to restore one        Immediately ]
AFW train to OPERABLE status.
CEOG STS                                 3.7.5-2                                 Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System 3.7.5 ACTIONS (continued)
CONDITION                             REQUIRED ACTION                            COMPLETION TIME EF. Required AFW train              EF.1       ---------------NOTE--------------
inoperable in MODE 4.                      LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.
Initiate action to restore one           Immediately AFW train to OPERABLE status.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                   FREQUENCY SR 3.7.5.1         Verify each AFW manual, power operated, and                             31 days automatic valve in each water flow path and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.
SR 3.7.5.2         -------------------------------NOTE------------------------------
Not required to be performed for the turbine driven AFW pump until [24] hours after reaching [800] psig in the steam generators.
Verify the developed head of each AFW pump at the                       In accordance flow test point is greater than or equal to the                         with the Inservice required developed head.                                                Testing Program CEOG STS                                            3.7.5-3                                   Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 BASES BACKGROUND (continued)
The AFW System is designed to supply sufficient water to the steam generator(s) to remove decay heat with steam generator pressure at the setpoint of the MSSVs. Subsequently, the AFW System supplies sufficient water to cool the unit to SDC entry conditions, and steam is released through the ADVs.
The AFW System actuates automatically on low steam generator level by the EFAS as described in LCO 3.3.42, "Engineered Safety Feature Actuation System (ESFAS) Instrumentation." The EFAS logic is designed to feed either or both steam generators with low levels, but will isolate the AFW System from a steam generator having a significantly lower steam pressure than the other steam generator. The EFAS automatically actuates the AFW turbine driven pump and associated DC operated valves and controls when required, to ensure an adequate feedwater supply to the steam generators. DC operated valves are provided for each AFW line to control the AFW flow to each steam generator.
The AFW System is discussed in the FSAR, Section [10.4.9] (Ref. 1).
APPLICABLE      The AFW System mitigates the consequences of any event with a loss of SAFETY          normal feedwater.
ANALYSES The design basis of the AFW System is to supply water to the steam generator to remove decay heat and other residual heat, by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest MSSV set pressure plus 3%.
The limiting Design Basis Accidents (DBAs) and transients for the AFW System are as follows:
: a. Feedwater Line Break (FWLB) and
: b. Loss of normal feedwater.
In addition, the minimum available AFW flow and system characteristics are serious considerations in the analysis of a small break loss of coolant accident.
CEOG STS                           B 3.7.5-2                              Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 BASES APPLICABILITY In MODES 1, 2, and 3, the AFW System is required to be OPERABLE and to function in the event that the MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace steam generator secondary inventory, lost as the unit cools to MODE 4 conditions.
In MODE 4, the AFW System may be used for heat removal via the steam generator.
In MODES 5 and 6, the steam generators are not normally used for decay heat removal, and the AFW System is not required.
ACTIONS       A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.
[ A.1 If one of the two steam supplies to the turbine driven AFW pumps is inoperable due to one inoperable steam supply, or if a turbine driven pump is inoperable for any reason while in MODE 3 immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable based on the following reasons:
: a. For the inoperability of a steam supply to the turbine driven AFW pump due to one inoperable steam supply, the 7 day Completion Time is reasonable since there is a redundant steam supply line for the turbine driven pump and the turbine driven train is still capable of performing its specified function for most postulated events.
: b. For the inoperability of a turbine driven AFW pump while in MODE 3 immediately subsequent to a refueling outage, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.
: c. For both the inoperability of a steam supply line to the turbine driven pump due to one inoperable steam supply and an inoperable turbine driven AFW pump while in MODE 3 immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps; and due to the low probability of an event requiring the use of the turbine driven AFW pump.
CEOG STS                          B 3.7.5-4                              Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 BASES ACTIONS (continued)
Condition A is modified by a Note which limits the applicability of the Condition for an inoperable turbine driven AFW pump in MODE 3 to when the unit has not entered MODE 2 following a refueling. Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical. ]
B.1 With one of the required AFW trains (pump or flow path) inoperable in MODE 1, 2, or 3 [for reasons other than Condition A], action must be taken to restore OPERABLE status within 72 hours. This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour Completion Time is reasonable based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA event occurring during this period. Two AFW pumps and flow paths remain to supply feedwater to the steam generators.
C.1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within [24] [48] hours. Assuming no single active failures when in this condition, the accident (a FLB or MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG. In this condition, the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis, [either due to the analysis requiring flow from two AFW pumps or due to the remaining AFW pump having to feed a faulted SG].
                  ------------------------------------REVIEWERS NOTE----------------------------------
Licensees should adopt the appropriate Completion Time based on their plant design. The 24 hour Completion Time is applicable to plants that can no longer meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump. The 48 hour Completion Time is applicable to plants that can still meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump.
CEOG STS                                 B 3.7.5-6                                          Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5
[The 24 hour Completion Time is reasonable based on the remaining OPERABLE steam supply to the turbine driven AFW pump, the availability of the remaining OPERABLE motor driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine driven AFW pump]
[The 48 hour Completion Time is reasonable based on the fact that the remaining motor driven AFW train is capable of providing 100 % of the AFW flow requirements, and the low probability of an event occurring that would challenge the AFW system.]
D.1 and D.2 When either Required Action A.1 [or ,B.1, C.1, or C.2] cannot be completed within the required Completion Time, [or if two AFW trains are inoperable in MODES 1, 2, and or 3 for reasons other than Condition C],
the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours, and in MODE 4 within [18] hours.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.
In MODE 4, with [two AFW trains inoperable in MODES 1, 2, and or 3],
operation is allowed to continue because only one motor driven AFW pump is required in accordance with the Note that modifies the LCO.
Although it is not required, the unit may continue to cool down and start the SDC.
CEOG STS                     B 3.7.5-7                             Rev. 3.1, 12/01/05

TSTF-412, Rev. 3 AFW System B 3.7.5 BASES ACTIONS (continued)
DE.1 Required Action DE.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status.
With all [three] AFW trains inoperable in MODES 1, 2, and or 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety grade equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status. LCO 3.0.3 is not applicable, as it could force the unit into a less safe condition.
EF.1 Required Action EF.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status.
With one AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status or to immediately verify, by administrative means, the OPERABILITY of a second train. LCO 3.0.3 is not applicable, as it could force the unit into a less safe condition.
In MODE 4, either the reactor coolant pumps or the SDC loops can be used to provide forced circulation as discussed in LCO 3.4.6, "RCS Loops - MODE 4."
SURVEILLANCE      SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the AFW water and steam supply flow paths provides assurance that the proper flow paths exist for AFW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulations; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.
CEOG STS                              B 3.7.5-8                               Rev. 3.1, 12/01/05}}