ML090080512

E-mail #1, Licensee'S Response to Request for Additional Information, Exigent License Amendment Request, Revise Technical Specification 3.7.1.7, Main Feedwater System, to Allow One-Time Allowed Outage Time (TAC No. ME0271

ML090080512
Person / Time
Site:	South Texas
Issue date:	12/31/2008
From:	Taplett K South Texas
To:	Thadani M Plant Licensing Branch IV
Thadani, M C, NRR/DORL/LPL4, 415-1476
References
TAC ME0271
Download: ML090080512 (3)

Text

From: Taplett, Kenneth [kjtaplett@STPEGS.COM]

Sent: Wednesday, December 31, 2008 1:38 PM To: Mohan Thadani Cc: Stanley Gardocki; Bruce Heida; Harrison, Albon

Subject:

RE: EXIGENT AMENDMENT Q@UESTION Attachments: FWIV exigent change - CIV discussion.doc Gentlemen, The STP response to a question I received today from Mohan Thadani regarding our application for an exigent change is attached. Please let me know if you need anything else regarding this matter.

Ken Taplett (361) 972-8416 From: Mohan Thadani [1]

Sent: Wednesday, December 31, 2008 11:59 AM To: Taplett, Kenneth Cc: Stanley Gardocki; Bruce Heida

Subject:

EXIGENT AMENDMENT Q@UESTION Ken:

I got your phone call message. Your response seems OK. Please send a copy to Bruce and Stan, who are on the CC list of this email.

Thanks for quick turnaround.

Have a Happy and prosperous New Year.

Mohan C Thadani Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation (301) 415-1476 Mohan.Thadani@nrc.gov E-mail Properties Mail Envelope Properties (582CA7E05607F14F8D433C5CE43C030A1BC8C0A3)

Subject:

RE: EXIGENT AMENDMENT Q@UESTION Sent Date: 12/31/2008 1:37:32 PM Received Date: 12/31/2008 1:37:32 PM From: Taplett, Kenneth Created By: kjtaplett@STPEGS.COM Recipients:

Mohan.Thadani@nrc.gov (Mohan Thadani)

Tracking Status: None Stanley.Gardocki@nrc.gov (Stanley Gardocki)

Tracking Status: None Bruce.Heida@nrc.gov (Bruce Heida)

Tracking Status: None awharrison@STPEGS.COM (Harrison, Albon)

Tracking Status: None Post Office:

exgmb2.CORP.STPEGS.NET Files Size Date & Time MESSAGE 57075 12/31/2008 FWIV exigent change - CIV discussion.doc 47168 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received:

Response to NRC Staff Question

Reference:

Letter from Charles T. Bowman, STPNOC, to the NRC Document Control Desk, dated December 19, 2008 License Amendment Request Proposed One-Time Exigent Change to Technical Specification 3.7.1.7, Main Feedwater System (NOC-AE-08002378 )

Note: The following question resulted from a phone conversation on December 31, 2008, between Mohan Thadani, NRC Senior Project Manager for the South Texas Project, and Ken Taplett, South Texas Project Licensing Engineer pertaining to the referenced application NRC Question: Discuss the containment isolation valve function of the feedwater isolation valves (FWIV) and provide further justification of the one-time extension of the allowed outage time of an inoperable but open FWIV from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

STPNOC Response: The feedwater isolation valves are containment isolation valves that meet General Design Criterion (GDC) 57 of Appendix A to 10 CFR 50. The feedwater isolation valves are in piping that is neither part of the reactor coolant pressure boundary nor connected directly to the containment atmosphere. The proposed one-time 24-hour action completion time is reasonable, based on operating experience and the low probability of an event occurring during this time period that would require isolation of the main feedwater flow paths to the steam generators.

Although South Texas Project TS 3.6.3, "Containment Isolation Valves", is not applied to an inoperable feedwater isolation valve because this valve has its own TS, the one-time request to extend the allowed outage completion time to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is consistent with the Completion Time allowed in TS 3.6.3. South Texas Project TS 3.6.3 allows with one or more isolation valves inoperable, at least one isolation barrier must be maintained operable in the affected penetration that is open and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (if the valve is not restored to an operable status) the affected penetration must be isolated by use of the deactivated automatic valve (in this case, the FWIV) secured in the isolation position. A GDC 57 closed system meets the requirement of an isolation barrier. In addition, the proposed one-time 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> allowed outage time is more conservative than ITS Condition C of TS 3.6.3, "Containment Isolation Valves", for one or more penetrations inoperable (applicable to penetration flow paths with only one containment isolation valve and a closed system) that allows a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time for an inoperable valve in this type of penetration.