ML22240A105
| ML22240A105 | |
| Person / Time | |
|---|---|
| Issue date: | 05/27/2015 |
| From: | NRC/NRR/DSS/STSB |
| To: | |
| Craig Harbuck NRR/DSS 301-415-3140 | |
| Shared Package | |
| ML22240A001 | List:
|
| References | |
| Download: ML22240A105 (21) | |
Text
GTST AP1000-A23-3.9.4, Rev. 1
Advanced Passive 1000 (AP1000)
Generic Technical Specification Traveler (GTST)
Title:
Revision of AP1000 GTS Subsection 3.9.4, Refueling Cavity Water Level
I. Technical Specifications Task Force (TSTF) Travelers, Approved Since Revision 2 of STS NUREG-1431, and Used to Develop this GTST
TSTF Number and
Title:
None
Not applicable
NRC Approval Date:
Not applicable
TSTF Classification:
Not applicable
Date report generated:
Wednesday, May 27, 2015 Page 1 GTST AP1000-A23-3.9.4, Rev. 1
II. Reference Combined License (RCOL) Standard Departures (Std. Dep.), RCOL COL Items, and RCOL Plant -Specific Technical Specifications (PTS) Changes Used to Develop this GTST
RCOL Std. Dep. Number and
Title:
None
RCOL COL Item Number and
Title:
Not applicable
RCOL PTS Change Number and
Title:
The Vogtle Electric Generating Plant Units 3 and 4 License Amendment Request (VEGP LAR) proposed the following changes to the initial version of the PTS (referred to as the current TS by the VEGP LAR).
These changes include Administrative Changes (A) and Less Restrictive Changes (L) and are addressed in enumerated discussions of change (DOCs). These changes are discussed in Sections VI and VII of this GTST.
DOC A038: Editorial/clarification change
DOC L05: Elimination of LCO 3.0.8
Date report generated:
Wednesday, May 27, 2015 Page 2 GTST AP1000-A23-3.9.4, Rev. 1
III. Comments on Relations Among TSTFs, RCOL Std. Dep., RCOL COL Items, and RCOL PTS Changes
This section discusses the considered changes that are: (1) applicable to operating reactor designs, but not to the AP1000 design; (2) already incorporated in the GTS; or (3) superseded by another change.
This subsection with its title is equivalent to Subsection 3.9.7 in WOG STS Rev. 4.
DOC A038 makes a minor editorial change for LCO SR 3.9.4.1 by eliminating the word that under Surveillance.
DOC L05 eliminates LCO 3.0.8 from LCO 3.9.4 Actions and from Bases 3.9.4 Actions.
Date report generated:
Wednesday, May 27, 2015 Page 3 GTST AP1000-A23-3.9.4, Rev. 1
IV. Additional Changes Proposed as Part of this GTST (modifications proposed by NRC staff and/or clear editorial changes or deviations identified by preparer of GTST)
APOG Recommended Changes to Improve Bases 3.9.4
Insert Chapter 15, Accident Analys es as Reference 1 in the list of references (APOG #499) and thus renumber the other references as Ref. 2 and Ref. 3.
Revise the reference numbers in Bases Background (APOG #495), Applicable Safety Analys es (APOG #496) and SR 3.9.4.1 Surveillance Requirements (APOG #498).
Delete the phrase refueling canal from Bases-Background. (APOG #495)
Change the phrase in containment to within containment in Bases-Applicability. (APOG
- 497)
Date report generated:
Wednesday, May 27, 2015 Page 4 GTST AP1000-A23-3.9.4, Rev. 1
V. Applicability
Affected Generic Technical Specifications and Bases:
Section 3.9.4, Refueling Cavity Water Level
Changes to the Generic Technical Specifications and Bases:
Eliminate in SR 3.9.4.1 Surveillance the word that from the phrase Verify that refueling cavity water level is where the word that is underlined. (DOC A038)
Eliminate LCO 3.0.8 from LCO 3.9.4 Actions and from Bases 3.9.4 Actions. (DOC L05)
Insert Chapter 15, Accident Analys es as Reference 1 in the list of references (APOG #499) and renumber the other references as Ref. 2 and Ref. 3.
Revise the reference numbers in Bases Background (APOG #495), Applicable Safety Analys es (APOG #496) and SR 3.9.4.1 Surveillance Requirements (APOG #498).
Delete the phrase refueling canal from Bases-Background. (APOG #495)
Change the phrase in containment to within containment in Bases-Applicability. (APOG
- 497)
Date report generated:
Wednesday, May 27, 2015 Page 5 GTST AP1000-A23-3.9.4, Rev. 1
VI. Traveler Information
Description of TSTF changes:
Not applicable
Rationale for TSTF changes:
Not applicable
Description of changes in RCOL St d. Dep.,RCOL COL Item(s), and RCOL PTS Changes:
Administrative Changes (A):
DOC A038:
In SR 3.9.4.1, the Surveillance is revised by eliminating the word that from the phrase Verify that refueling cavity water level is where the word that is underlined.
Less Restrictive Changes (L):
DOC L05:
The reference to LCO 3.0.8 is eliminated in TS LCO Actions Note and Bases Actions for this subsection. The changes are highlighted later in the Markup of this subsection at the end of this GTST.
Rationale for changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes:
According to DOC A038, deletion of 'that' from Surveillances is consistent with the guidance provided in TSTF-GG 01, subsection 3.1.1.g, that states: Avoid the use of 'that' in the Specifications if the statement is clear without it.Deleting 'that' from the current SRs does not reduce the clarity of the SRs.
In reference to the elimination of LCO 3.0.8, DOC L05 indicates that current TS LCO 3.0.8 applies in Modes 5 and 6 when the associated Actions are not met or an associated Action is not provided. In some cases, LCO 3.0.8 is explicitly excluded from applying by way of a Note.
In conjunction with the change to eliminate LCO 3.0.8, these Notes are no longer necessary and are administratively eliminated. VEGP TSU DOC concludes that, removing LCO 3.0.8 (and references to it) will not adversely impact public health and safety.
Accordingly, the changes made by DOC A038 and DOC L05 are acceptable. Furthermore, these changes are consistent with WOG STS 3.9.7, Rev. 4 (which is equivalent to GTS 3.9.4).
Therefore, these changes are implemented by this GTST in AP1000 STS 3.9.4, Rev. 0.
Date report generated:
Wednesday, May 27, 2015 Page 6 GTST AP1000-A23-3.9.4, Rev. 1
Description of additional changes proposed by NRC staff/preparer of GTST :
None
Rationale for additional changes proposed by NRC staff/preparer of GTST :
Not applicable
Date report generated:
Wednesday, May 27, 2015 Page 7 GTST AP1000-A23-3.9.4, Rev. 1
VII. GTST Safety Evaluation
Technical Analysis:
Technical discussion for the changes proposed by DOC A038 and DOC L05 are covered in the section VI of this GTST under Rationale for changes in RCOL Std. Dep., RCOL COL Item(s),
and RCOL PTS Changes.
References to Previous NRC Safety Evaluation Reports (SERs) :
None
Date report generated:
Wednesday, May 27, 2015 Page 8 GTST AP1000-A23-3.9.4, Rev. 1
VIII. Review Information
Evaluator Comments:
None
Joseph C. Braun Argonne National Laboratory 630-252-5574 joebraun@anl.gov
E. Danial Doss Argonne National Laboratory 630-252-5967 doss@anl.gov
Review Information:
Availability for public review and comment on Revision 0 of this traveler approved by NRC staff on 4/23/2014.
APOG Comments (Ref. 7) and Resolutions:
- 1. (Internal #495, #496, #498, #499) 3.9.4, Bases: APOG recommends (# 499) inserting Chapter 15, Accident Analys es as Reference 1 in the list of references and thus renumbering the other references as Ref. 2 and Ref. 3. Accordingly, APOG recommends revising the reference numbers in Bases Background (#495), Applicable Safety Analys es
(#496) and SR 3.9.4.1 Surveillance Requirements (#498).
Throughout the Bases, references to Sections and Chapters of the FSAR do not include the FSAR clarifier. Since these Section and Chapter references are to an external document, it is appropriate (APOG #3) to include the FSAR modifier. This is resolved by adding the FSAR modifier as appropriate.
- 2. (Internal #495) 3.9.4, Bases
Background:
APOG recommends deleting the phrase refueling canal.APOG comments that this is an editorial change that provides improved clarity, consistency, and operator usability. This change is made as recommended to improve the Bases.
- 3. (Internal #497) 3.9.4, Bases Applicability: APOG recommends changing the phrase in containment to within containment.APOG comments that this is an editorial change that provides improved clarity, consistency, and operator usability. This change is made as recommended to improve the Bases.
Date report generated:
Wednesday, May 27, 2015 Page 9 GTST AP1000-A23-3.9.4, Rev. 1
NRC Final Approval Date:05/27/2015
NRC
Contact:
Derek Scully U.S. Nuclear Regulatory Commission 301-415-6972 Derek.Scully@nrc.gov
Date report generated:
Wednesday, May 27, 2015 Page 10 GTST AP1000-A23-3.9.4, Rev. 1
IX. Evaluator Comments for Consideration in Finalizing Technical Specifications and Bases
None
Date report generated:
Wednesday, May 27, 2015 Page 11 GTST AP1000-A23-3.9.4, Rev. 1
X. References Used in GTST
- 1. AP1000 DCD, Revision 19, Section 16, Technical Specifications, June 2011 (ML11171A500).
- 2. Southern Nuclear Operating Company, Vogtle Electric Generating Plant, Units 3 and 4, Technical Specifications Upgrade License Amendment Request, February 24, 2011 (ML12065A057).
- 3. NRC Safety Evaluation (SE) for Amendment No. 13 to Combined License (COL) No. NPF-91 for Vogtle Electric Generating Plant (VEGP) Unit 3, and Amendment No. 13 to COL No.
NPF-92 for VEGP Unit 4, September 9, 2013, ADAMS Package Accession No.
ML13238A337, which contains:
ML13238A355 Cover Letter - Issuance of License Amendment No. 13 for Vogtle Units 3 and 4 (LAR 12-002).
ML13238A359 Enclosure 1 - Amendment No. 13 to COL No. NPF-91 ML13239A256 Enclosure 2 - Amendment No. 13 to COL No. NPF-92 ML13239A284 Enclosure 3 - Revised plant-specific TS pages (Attachment to Amendment No. 13)
ML13239A287 Enclosure 4 - Safety Evaluation (SE), and Attachment 1 - Acronyms ML13239A288 SE Attachment 2 - Table A - Administrative Changes ML13239A319 SE Attachment 3 - Table M - More Restrictive Changes ML13239A333 SE Attachment 4 - Table R - Relocated Specifications ML13239A331 SE Attachment 5 - Table D - Detail Removed Changes ML13239A316 SE Attachment 6 - Table L - Less Restrictive Changes
The following documents were subsequently issued to correct an administrative error in Enclosure 3:
ML13277A616 Letter - Correction To The Attachment (Replacement Pages) - Vogtle Electric Generating Plant Units 3 and 4-Issuance of Amendment Re:
Technical Specifications Upgrade (LAR 12-002) (TAC No. RP9402)
ML13277A637 Enclosure 3 - Revised plant-specific TS pages (Attachment to Amendment No. 13) (corrected)
- 4. TSTF-GG 01, Writer's Guide for Plant-Specific Improved Technical Specifications, June 2005.
- 5. RAI Letter No. 01 Related to License Amendment Request (LAR)12-002 for the Vogtle Electric Generating Plant Units 3 and 4 Combined Licenses, September 7, 2012 (ML12251A355).
- 6. Southern Nuclear Operating Company, Vogtle Electric Generating Plant, Units 3 and 4, Response to Request for Additional Information Letter No. 01 Related to License Amendment Request LAR-12-002, ND-12-2015, October 04, 2012 (ML12286A363 and ML12286A360).
Date report generated:
Wednesday, May 27, 2015 Page 12 GTST AP1000-A23-3.9.4, Rev. 1
- 7. APOG-2014 -008, APOG (AP1000 Utilities) Comments on AP1000 Standardized Technical Specifications (STS) Generic Technical Specification Travelers (GTSTs), Docket ID NRC-2014-0147, September 22, 2014 (ML14265A493).
Date report generated:
Wednesday, May 27, 2015 Page 13 GTST AP1000-A23-3.9.4, Rev. 1
XI. MARKUP of the Applicable GTS Subsection for Preparation of the STS NUREG
The entire section of the Specifications and the Bases associated with this GTST is presented next.
Changes to the Specifications and Bases are denoted as follows: Deleted portions are marked in strikethrough red font, and inserted portions in bold blue font.
Date report generated:
Wednesday, May 27, 2015 Page 14 GTST AP1000-A23-3.9.4, Rev. 1
Refueling Cavity Water Level 3.9.4
3.9 REFUELING OPERATIONS
3.9.4 Refueling Cavity Water Level
LCO 3.9.4 Refueling Cavity Water Level shall be maintained 23 ft above the top of the reactors flange.
fCAifT airradiated fuel si within contai
Afl Tb ls not applica
ClNaN na AflN ClibTff
A. oefueliavi 1 pent of mediy litn limi irradiated fu assies within contaient.
prosbfiiANCbbnMbp
prosbfiiANCb cnN
po 3.V.4.1 si that refueling cavity water level is 23 ft above 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the top of reactor vessel flange.
AP1000 STS 3.9.4-1 Amendment 0Rev. 0 Revision 19 Date report generated:
Wednesday, May 27, 2015 Page 15 GTST AP1000-A23-3.9.4, Rev. 1
Refueling Cavity Water Level B 3.9.4
B 3.9 REFUELING OPERATIONS
B 3.9.4 Refueling Cavity Water Level
BASES
BACKGROUND The movement of irradiat ed f uel as semblies within containment requires a minimum water lev el of 23 ft above t he t op o f t he r eactor vessel flange.
During ref ueli ng, this maintai ns sufficient water lev el in containm ent,
refueli ng cavity, refueling canal,f uel transf er canal, and spent f uel pool to retain iodi ne fi ssi on product activity in t he ev ent of a f uel handli ng accident (Refs. 12 and 23). Sufficient i odi ne activity w ould be retained t o limit offsite doses fro m the accident to within the val ues report ed i n FSAR Chapt er 1 5 (Ref. 1).
APPLICABLE During movement of irradiat ed f uel assemblies, t he wat er lev el in the SAFETY refueli ng cavity and t he ref ueli ng canal is an initi al conditi on design ANALYSES parameter in the analysis of a f uel-handli ng accident in containment, as postulated by Regulatory Guide 1. 183 (Ref. 12).
The f uel handli ng accident analysis i nside containm ent is described i n Reference 23. This analysis assumes a minimum wat er lev el of 23 f eet.
Refueli ng Cavity Water Level satisf ies Criterion 2 of 10 CFR 50. 36(c )(2 )(ii).
LCO A minimum ref ueli ng cavity water lev el of 23 f t above the r eactor v essel flange is required to ensure t hat the r adiologi cal conseq uen ces of a postulated f uel handli ng accident inside containment are within t he values cal culated in Refer ence 2.
APPLICABILITY Refueli ng Cavity Water Level is appli cable w hen movi ng irr adiat ed f uel assemblies inwithin containment. The LC O minimizes the possibility of radi oactive release due to a f uel handli ng accident in containment that is beyond t he assumptions of the safety analysi s. If i rradiat ed f uel assemblies are not being mov ed in containment, there can be no significant radi oactivity rel ease as a resul t of a p ostulated f uel handli ng accident. Requirements for f uel handli ng accidents in the spent f uel pool are covered by LCO 3.7.5, Spent Fuel P ool Water Level.
AP1000 STS B 3.9.4-1 Amendment 0Rev. 0 Revision 19 Date report generated:
Wednesday, May 27, 2015 Page 16 GTST AP1000-A23-3.9.4, Rev. 1
Refueling Cavity Water Level B 3.9.4
BASES
ACTIONS LCO 3.0.8 is appli cable wh ile in MOD E 5 or 6. Si nce i rradiat ed f uel assembly movement can occur in MODE 5 or 6, the ACT IONS have been modifi ed by a Note stating that LCO 3.0.8 is not a ppli cabl e. If movi ng irradiat ed f uel assemblies while in MOD E 5 or 6, the f uel movement is independent of shutdown r eact or operati ons. Entering LCO 3.0.8 wh ile i n MODE 5 or 6 w ould require t he optimizati on of pla nt safety, unnecessarily.
A.1
With a water lev el of < 23 ft above t he t op o f t he r eactor vessel flange, all operations involving movem ent of irradiat ed f uel assemblies within containment shal l be suspended imm ediately to e nsure t hat a f uel handling accident cannot occur.
The suspension o f f uel movement shal l not pr eclude completion o f movement to safe position.
SURVEILLANCE SR 3.9.4 1 REQUIREMENTS Verification of a minimum water lev el of 23 f t above the t op of t he r eactor vessel flange ensures that the design basis for the analysis of th e postulated f uel handli ng accident during ref ueling operati ons is met.
Water at t he required lev el above t he top o f t he re actor vessel flange limits the consequences of damaged fuel rods that are postulat ed t o resul t fro m a fuel handling accident inside containment (Ref. 23).
The Freq uency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is based on engi neeri ng judgme nt and i s consider ed adequate in view of t he large volume of wat er and t he no rmal procedur al controls of valve positions which make significant unplanned level changes unli kely.
REFERENCES 1. FSAR Chapter 15, Accident Analyse s.
- 12. Regulatory Guide 1. 183, Alternate Radiologi cal S our ce Terms for Evaluati ng D esign Basis Acci dents at N uclear Power R eactors.
- 23. FSAR Section 15.7. 4, Fuel Handli ng A cci dent.
AP1000 STS B 3.9.4-2 Amendment 0Rev. 0 Revision 19 Date report generated:
Wednesday, May 27, 2015 Page 17 GTST AP1000-A23-3.9.4, Rev. 1
XII. Applicable STS Subsection After Incorporation of this GTST s Modifications
The entire sub section of the Specifications and the Bases associated with this GTST, following incorporation of the m odifications, is presented next.
Date report generated:
Wednesday, May 27, 2015 Page 18 GTST AP1000-A23 -3.9.4, Rev. 1
Refueling Cavity Water Level 3.9.4
3.9 REFUELING OPERATIONS
3.9.4 Refueling Cavity Water Level
LCO 3.9.4 Refueling Cavity Water Level shall be maintained 23 ft above the top of the reactors ange.
fCAifT airradiated fuel si within contai
Afl
ClNaN na AflN ClibTff
oefueliavi 1 pent of mediy litn limi irradiated fu assies within contaient.
prosbfiiANCbbnMbp
prosbfiiANCb cnN
po 3.V.4.1 Verify refueling cavity water level is 23 ft above the 24 s eacrs ge.
AP1000 STS 3.9.4-1 Rev. 0
Date report generated:
Wednesday, May 27, 2015 Page 19 GTST AP1000-A23 -3.9.4, Rev. 1
Refueling Cavity Water Level B 3.9.4
B 3.9 REFUELING OPERATIONS
B 3.9.4 Refueling Cavity Water Level
BASES
BACKGROUND The movement of irradi ated fuel as semblies within containment requires a minimum water level of 23 ft abov e the top of the reactor vessel flange.
During refueli ng, this maintains sufficient water level in cont ainment,
refueli ng cavity, fuel tran sfer cana l, and spen t fuel pool to retain iodi ne fissi on product activity in the event of a fuel handli ng accident (Refs. 2 and 3). Sufficient iodi ne activity woul d be retained to limit offsite doses from the accident to within the values repor ted in FSAR Chapter 15 (Ref. 1).
APPLICABLE During movement of irradiated fuel assemblies, the water level in the SAFETY refueli ng cavity and the refueli ng canal is an initial condi tion design ANALYSES parameter in the anal ysis of a fuel-handli ng accident in containment, as postulated by Regulatory Guide 1.183 (Ref. 2).
The fuel handli ng accident anal ysis inside cont ainment is described in Reference 3. This analysis assumes a minimum water level of 23 feet.
Refueli ng Cavity Water Level sat isfies Criterion 2 of 10 CFR 50. 36( c)(2 )(ii ).
LCO A minimum refueli ng cavity water level of 23 ft above the reac tor vessel flange is required to ensure that the radi ological conseq uen ces of a postulated fuel handli ng accident inside containment are within the values cal culated in Reference 2.
APPLICABILITY Refueli ng Cavity Water Level is appli cabl e when moving irradi ated fuel assemblies within containment. The LCO minimizes the possibility of radi oactive re lease due to a fuel handli ng accident in containment that is beyond the assumptions of the safety anal ysis. If irradi ated fuel assemblies are not bei ng moved in containment, ther e can be no significant radi oac tivity re lease as a resul t of a postulated fuel handli ng accident. Requirements for fuel handli ng accidents in the spent fuel pool are covered by LCO 3.7.5, Spent Fuel P ool Water Lev el.
AP1000 STS B 3.9.4-1 Rev. 0
Date report generated:
Wednesday, May 27, 2015 Page 20 GTST AP1000-A23-3.9.4, Rev. 1
Refueling Cavity Water Level B 3.9.4
BASES
ACTIONS A.1
With a water lev el of < 23 ft above t he t op o f t he r eactor vessel flange, all operations involving movem ent of irradiat ed f uel assemblies within containment shal l be suspended imm ediately to e nsure t hat a f uel handling accident cannot occur.
The suspension o f f uel movement shal l not pr eclude completion o f movement to safe position.
SURVEILLANCE SR 3.9.4 1 REQUIREMENTS Verification of a minimum water lev el of 23 f t above the t op of t he r eactor vessel flange ensures that the design basis for the analysis of th e postulated f uel handli ng accident during ref ueling operati ons is met.
Water at t he required lev el above t he top o f t he re actor vessel flange limits the consequences of damaged fuel rods that are postulat ed t o resul t fro m a fuel handling accident inside containment (Ref. 3).
The Freq uency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is based on engi neeri ng judgme nt and i s consider ed adequate in view of t he large volume of wat er and t he no rmal procedur al controls of valve positions which make significant unplanned level changes unli kely.
REFERENCES 1. FSAR Chapter 15, Accident Analys es.
- 2. Regulatory Guide 1. 183, Alternate Radiologi cal S our ce Terms for Evaluati ng D esign Basis Acci dents at N uclear Power R eactors.
- 3. FSAR Section 15.7. 4, Fuel Handli ng A cci dent.
AP1000 STS B 3.9.4-2 Rev. 0
Date report generated:
Wednesday, May 27, 2015 Page 21