ML063200465

Supplement to Proposed Technical Specification Change (LBDCR 04-MP2-013) Auxiliary Feedwater System Allowed Outage Time

ML063200465
Person / Time
Site:	Millstone
Issue date:	11/16/2006
From:	Gerald Bichof Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
05-699B
Download: ML063200465 (18)

Text

Dominion Nuclear Connecticut, Inc.

5000 Dominion Boulevard, Glen Allen, Virgin~d2.3060 Wcb Address: www.dorn.com November 16, 2006 U. S. Nuclear Regulatory Commission Serial No. 05-6998 Attention: Document Control Desk NLOSIPRW RO One White Flint North Docket No. 50-336 11555 Rockville Pike License No. DPR-65 Rockville, MD 20852-2738 DOMINION NUCLEAR CONNECTICUT. INC.

MILLSTONE POWER STATION UNIT 2 SUPPLEMENT TO PROPOSED TECHNICAL SPECIFICATION CHANGE

/LBDCR 04-MP2-013)

AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME This letter provides supplemental information for request LBDCR 04-MP2-013, which was submitted by Dominion Nuclear Connecticut, Inc. (DNC) in a letter dated February 7, 2006, for Millstone Power Station Unit 2. The submittal was initially supplemented in a letter dated August 14, 2006. Attachment 1 of this letter provides clarifications requested by the NRC in a conference call with DNC on November 9, 2006. Attachments 2 and 3 provide the replacement marked up page and retyped pages. The revised marked up bases page is provided in Attachment 4 for information only.

The additional information provided in this letter does not affect the conclusions of the safety summary and significant hazards consideration discussion in DNC's submittal of February 7, 2006.

In accordance with 10 CFR 50.91 (b), a copy of this letter is being provided to the State of Connecticut.

If you should have any questions regarding this submittal, please contact Mr. Paul R. Willoughby at (804) 273-3572.

Very truly yours, Gerald T. Bischof "

Vice President - Nuclear Engineering Commitments made in this letter: None

Serial No. 05-6996 Docket No. 50-336 Supplement to Proposed Technical Specification Change Request Auxiliary Feedwater System Allowed Outage Time Page 2 of 3 Attachments: (4)

1. Supplement to Proposed Technical Specification Change

2. Replacement Marked Up Page

3. Replacement Retyped Pages

4. Revised Marked Up Bases Page (Information Only) cc: U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415 Mr. V. Nerses Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8 C2 Rockville, MD 20852-2738 Mr. S. M. Schneider NRC Senior Resident Inspector Millstone Power Station Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127

Serial No. 05-699B Docket No. 50-336 Supplement to Proposed Technical Specification Change Request Auxiliary Feedwater System Allowed Outage Time Page 3 of 3 COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO 1 The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this 16%day of -n , 2006.

My Commission Expires: &z~41+3(, 2008 .

0 Notary Public (SEAL)

Serial No. 05-6998 Docket No. 50-336 ATTACHMENT 1 AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME SUPPLEMENT TO PROPOSED TECHNICAL SPECIFICATION CHANGE DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

Serial No. 05-699B Docket No. 50-336 Attachment 1, Page 1 of 2 SUPPLEMENT TO PROPOSED TECHNICAL SPECIFICATION CHANGE AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME This letter provides supplemental information for request LBDCR 04-MP2-013, submitted by Dominion Nuclear Connecticut, Inc. (DNC) in a letter dated February 7 , 2006, for Millstone Power Station Unit 2. The submittal was supplemented in a letter dated August 14, 2006. This attachment provides clarifications requested by the NRC in a conference call with DNC on November 9, 2006, in which the NRC requested additional information to facilitate the technical review being conducted by the staff.

Question 1 The proposed change to Millstone Power Station Unit 2 (MPS 2) TS 3.7.1.2 ACTIONS includes an asterisked footnote that discusses separate condition entry for selected specified ACTIONS. Please explain the necessity and basis for the footnote.

Response 1 Based on the perspective provided by the NRC during a conference call between DNC and the NRC on November 9, 2006, the referenced footnote and its basis were reviewed. It was concluded that the footnote was not required. Also as a result of the discussions during the conference call, the description of the inoperable equipment for ACTION a. is also being clarified. The emphasis in the description of the inoperable equipment is changed from an inoperable steam supply to an inoperable auxiliary feedwater pump due to an inoperable steam supply. provides the revised marked up page and includes a revision to Insert A provided in the original proposal (DNC Serial No.05-699, dated February 7, 2006) that removes the footnote and the asterisks and clarifies the ACTION a. inoperable equipment description. Replacement retyped pages are provided in Attachment 3 of this letter.

Additionally, the changes to the Technical Specification Bases that were previously provided for information only will be further modified to address the above changes. The revised marked up page of the Technical Specification Bases is provided in Attachment 4 of this letter for information only.

Serial No. 05-699B Docket No. 50-336 Attachment 1, Page 2 of 2 Question 2 Please explain the purpose of the word "required" in proposed MPS 2 TS 3.7.1.2 Required Action c.

Response 2 Upon review, the word "required" was determined to be unnecessary. Although present in the current Technical Specification, it has no explicit value and will be removed. provides the revised marked up page and includes a revision to Insert A provided in the original proposal (DNC Serial No.05-699, dated February 7, 2006) that removes the word "required" in proposed Required Action c. Replacement retyped pages are provided in Attachment 3 of this letter.

Serial No. 05-6998 Docket No. 50-336 ATTACHMENT 2 AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME REPLACEMENT MARKED UP PAGE DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

AUXILIARY FEEDWmR PUMPS LIMITING CONDITION FOR OPERATION 3.7.1.2 At least three steam generator auxiliary feedwater pumps shall be OPERABLE with:

a. Two feedwater pumps capable of being powered from separate OPERABLE emergency busses, and b, One feedwater pump capable of being powered from an OPERABLE steam suppiy system.

APPLJCABILITY: MODES 1,2and 3.

following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Ieast HOT STANDBY

/

SURVEILLANCE REQUIREMENTS 4.7.1.2 Each auxiliary fedwater pump shall be demonstrated OPERABLE:

a. At least once per 3 1 days by verivig each auxfiary feedwater manual, power operated, and automatic valve in each water flow path and in each steam supply flow path to the steam turbine driven pump,that is not locked, sealed, or othemise secured in position, is in the correct:position.

b. By verifying the developed head of each auxiliary f d r purnp at the flow test point is greater than or equal to the required developed head when tested pursuant to Specification4.0.5. (Not required to be performed for the steam turbine driven auxiliary feedwater pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 800 psig in the steam generators. The provisions of Specification 4.0.4 q e not appticable to the steam turbine driven auxiliary feedwater purnp for entry into MODE 3.

h4ILLSTONE - UNIT 2 Amendment No. 63,76,98,W, 234, w

Serial No. 05-6999 Docket No. 50-336 Attachment 2 Inserts Page 1 of 2 Revised Insert A Millstone Power Station Unit 2 Technical Specifications Page 314 7-4 Inoperable Equipment Required ACTION

a. Turbine-driven auxiliary a. Restore affected equipment to OPERABLE status feedwater pump due to within 7 days. If these ACTIONS are not met, one steam supply being be in at least HOT STANDBY within the next 6 inoperable. hours and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. Restore affected equipment to OPERABLE status within 7 days. If these ACTIONS are not met,

---

NOTE------------- be in at least HOT SHUTDOWN within the Only applicable if MODE following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

2 has not been entered following REFUELING.

One turbine-driven auxiliary feedwater pump in MODE 3 following REFUELING.

c. One auxiliary feedwater c. Restore the auxiliary feedwater pump to pump in MODE 1,2, or 3 OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If these for reasons other than a. ACTIONS are not met, be in at least HOT or b. above. STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

d. Two auxiliary feedwater d. Be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pumps in MODE 1,2, or in HOT SHUTDOWN within the following 12

3. hours.

Serial No. 05-6998 Docket No. 50-336 Attachment 2 Inserts Page 2 of 2 Inoperable Equipment Reauired ACTION

e. Three auxiliary feedwater e.

pumps in MODE 1, 2, or .......................... NOTE.............................

3. L C 0 3.0.3 and all other L C 0 required ACTIONS requiring MODE changes are suspended until one AFW pump is restored to OPERABLE status.

Immediately initiate ACTION to restore one auxiliary feedwater pump to OPERABLE status.

Serial No. 05-6996 Docket No. 50-336 ATTACHMENT 3 AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME REPLACEMENT RETYPED PAGES DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

PLANT SYSTEMS AUXILIARY FEEDWATER PUMPS LIMITING CONDITION FOR OPERATION 3.7.1.2 At least three steam generator auxiliary feedwater pumps shall be OPERABLE with:

a. Two feedwater pumps capable of being powered from separate OPERABLE emergency busses, and

b. One feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABILITY: MODES 1 , 2 and 3.

ACTION:

operable Equipment Required ACTION Turbine-driven auxiliary a. Restore affected equipment to OPERABLE status within feedwater pump due to one 7 days. If these ACTIONS are not met, be in at least steam supply being inoperable. HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. Restore affected equipment to OPERABLE status within 7 days. If these ACTIONS are not met, be in at least

--- HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

-NOTE - - - -

Only applicable if MODE 2 has not been entered following REFUELING One turbine-driven auxiliary feedwater pump in MODE 3 following REFUELING One auxiliary feedwater pump c. Restore the auxiliary feedwater pump to OPERABLE in MODE 1,2, or 3 for reasons status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If these ACTIONS are not met, other than a. or b. above. be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Two auxiliary feedwater d. Be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in pumps in MODE l , 2 , or 3. HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

MILLSTONE - UNIT 2 314 7-4 Amendment No. a,%, #,M,236, m,

PLANT SYSTEMS AUXILIARY FEEDWATER PUMPS LIMITING CONDITION FOR OPERATION ACTION: (Continued) operable Equipment tequired ACTION Three auxiliary feedwater pumps in MODE 1,2, or 3.

L C 0 3.0.3 and all other L C 0 required ACTIONS requiring MODE changes are suspended until one AFW pump is restored to OPERABLE status.

Immediately initiate ACTION to restore one auxiliary feedwater pump to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.7.1.2 Each auxiliary feedwater pump shall be demonstrated OPERABLE:

a. At least once per 3 1 days by verifying each auxiliary feedwater manual, power operated, and automatic valve in each water flow path and in each steam supply flow path to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

b. By verifying the developed head of each auxiliary feedwater pump at the flow test point is greater than or equal to the required developed head when tested pursuant to Specification 4.0.5. (Not required to be performed for the steam turbine driven auxiliary feedwater pump until 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 800 psig in the steam generators. The provisions of Specification 4.0.4 are not applicable to the steam turbine driven auxiliary feedwater pump for entry into MODE 3.)

MILLSTONE - UNIT 2 Amendment No. 32,63,283,

PLANT SYSTEMS AUXILIARY FEEDWATER PUMPS SURVEILLANCE REQUlREMENTS (Continued)

c. At least once per 18 months by verifying each auxiliary feedwater automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position, as designed, on an actual or simulated actuation signal.

d. At least once per 18 months by verifying each auxiliary feedwater pump starts automatically, as designed, on an actual or simulated actuation signal.

e. By verifying the proper alignment of the required auxiliary feedwater flow paths by verifying flow from the condensate storage tank to each steam generator prior to entering MODE 2 whenever the unit has been in MODE 5, MODE 6, or defueled for a cumulative period of greater than 30 days.

MILLSTONE - UNIT 2 Amendment No.

Serial No. 05-6998 Docket No. 50-336 ATTACHMENT 4 AUXILIARY FEEDWATER SYSTEM ALLOWED OUTAGE TIME REVISED MARKED UP BASES PAGE

/INFORMATION ONLY)

DOMINION NUCLEAR CONNECTICUT, INC.

MILLSTONE POWER STATION UNIT 2

314.7 PJ,ANT SYSTEMS BASES PUMPS (Continued]

During quarterly surveillancetesting of the turbine driven AFW pump, valve 2-CN-27A is closed and valve 2-CN-28 is opened to prevent overheating the water being circulated, In this configuration, the suction of the turbine driven AFW pump is aligned to the Condensate Storage Tank via the motor driven AlFW pump su~tionflow path, and the pump minimum flow is directed to the Condensate Storage %k by the turbine driven AFW pump suction path upstream of 2-CN-27A in the reverse direction. During this surveillance, the suction path to the motor driven AFW pump suction path remains OPERABLE, and the turbine driven AFW suction path is inoperable. Ln this situation, the ACTION requirements of Technical Specification 3.7.1.2 for one A F W pump are applicable. d Surveillance Requirement 4.7.1.2.averifies the correct alignment for manual, power operated, and automatic valves in the Auxiliary Feedwater ( A m ) System flow paths (water and steam) to provide assuraace that the proper flow paths will exist for AFW operation. This surveillance does not apply to valves that are locked, sealed, or otherwise secured m position, since Pese valves were verified to be in the conect position prior to locking, sealing, or securing. A valve that receives an actuation signal is allowed to be in a nonaccideni position provided the valve automatically repositions within the proper stroke time. 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. The 31 day frequency is appropriate because the valves are operated under procedural control and an improper valve position would only affect a single train. This frequency has been shown to be acceptablethrough operating experience.

Surveiilance Requirement 4.7. I .2.b, which addresses periodic surveillance testing of the AFW pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems, is required by Section XI ofthe ASME Code. This type oftesting may be accompIishedby memuringthe pump developed head at only one point of the pump characteristic cunre- This verifies both that the measumd pedormance is within an accepCabIe tolerance ofthe original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the unit safety analysis. The surveillance requirements are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.

Section XI of the A S m Code provides the activities and frequencies necessary to satisfy the requirements. This surveillance is modified to indicate thst the teat can be deferred for the steam driven A F W pump until suitable plant conditions art established. This deferral is required because steam pressure is not sufficient to perform the test urrtii after However, the test, if required, must be performed prior to entering MODE 2.

MILLSTONE UNIT 2- B 314 7-2b Amendment No.5?, #,63,% I+,

?36, zv

Serial No. 05-699B Docket No. 50-336 Attachment 4 Inserts Page 1 of 2 Revised Insert E Millstone Power Station Unit 2 Technical Specifications Page B 314 7-2b If the turbine-driven auxiliary feedwater train is inoperable due to an inoperable steam supply in MODES 1, 2, and 3, or if the turbine-driven auxiliary feedwater pump is inoperable 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 allowed outage time is reasonable, based on the following:

a. For the inoperability of the turbine-driven auxiliary feedwater pump due an inoperable steam supply, the 7 day allowed outage time is reasonable since the auxiliary feedwater system design affords adequate redundancy for the steam supply line for the turbine-driven pump,

b. For the inoperability of a turbine-driven auxiliary feedwater pump while in MODE 3 immediately subsequent to a refueling, the 7 day allowed outage time is reasonable due to the minimal decay heat levels in this situation.

c. For both the inoperability of the turbine-driven pump due to an inoperable steam supply and an inoperable turbine-driven auxiliary feedwater pump while in MODE 3 immediately following a refueling outage, the 7 day allowed outage time is reasonable due to the availability of redundant OPERABLE motor driven auxiliary feedwater pumps, and due to the low probability of an event requiring the use of the tu rbine-driven auxiliary feedwater pump.

When one steam supply to the turbine-driven auxiliary feedwater pump is inoperable, the turbine-driven auxiliary feedwater pump is inoperable. In this case, although the turbine-driven auxiliary feedwater pump with a single operable steam supply is capable of performing its safety function in the absence of a single failure, the turbine-driven auxiliary feedwater pump is considered inoperable due to the lack of redundancy with respect to steam supplies.

The required ACTION dictates that if the 7 day allowed outage time is reached the unit must be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

Serial No. 05-6998 Docket No. 50-336 Attachment 4 Inserts Page 2 of 2 The allowed time is reasonable, based on operating experience, to reach the required conditions from full power conditions in an orderly manner and without challenging plant systems.

A Note limits the applicability of the inoperable equipment condition b. to when the unit has not entered MODE 2 following a REFUELING. Required ACTION b. allows one auxiliary feedwater pump to be inoperable for 7 days vice the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time in required ACTION c. This longer allowed outage time is based on the reduced decay heat following REFUELING and prior to the reactor being critical.

With one of the auxiliary feedwater pumps inoperable in MODE 1, 2, or 3 for reasons other than ACTION a. or b., ACTION must be taken to restore the inoperable equipment to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This includes the loss of both steam supply lines to the turbine-driven auxiliary feedwater pump.

The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> allowed outage time is reasonable, based on redundant capabilities afforded by the auxiliary feedwater system, time needed for repairs, and the low probability of a DBA occurring during this time period. Two auxiliary feedwater pumps and flow paths remain to supply feedwater to the steam generators.

If all three AFW pumps 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 non-safety 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 A W pump to OPERABLE status. Required ACTION e. is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW pump is restored to OPERABLE status. In this case, L C 0 3.0.3 is not applicable because it could force the unit into a less safe condition.