watts bar - unit 1 - technical specification change 09-10 - … · atlanta, georgia 30303 mr....

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000

JUN 0 5 2009TVA-WBN-TS-09-1 0 10 CFR 50.90

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D. C. 20555-0001

Gentlemen:

In the Matter of the ) Docket No. 50-390Tennessee Valley Authority )

WATTS BAR NUCLEAR PLANT (WBN) - UNIT 1 - TECHNICAL SPECIFICATION (TS)CHANGE 09-10 - REQUEST TO CORRECT LOGIC CONNECTOR BETWEEN TS 3.3.2,"ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS)INSTRUMENTATION," CONDITION I, ACTIONS 1.2.1 AND 1.2.2

Pursuant to 10 CFR 50.90, Tennessee Valley Authority (TVA) is submitting a request for TSchange (WBN-TS-09-10) to License NPF-90 for WBN Unit 1. The proposed amendmentwill correct an error by changing a logic connector from "OR" to "AND" between TS 3.3.2,"ESFAS Instrumentation," Condition I, Actions 1.2.1 and 1.2.2. This change will restoreconsistency with other similar TS actions. This error was apparently introduced during thedevelopment of the Unit 1 TSs prior to Unit 1 Licensing but was only recently identified.

The enclosure provides TVA's evaluation of the proposed change. TVA has determinedthat there are no significant hazards considerations associated with the proposed changeand that the TS change qualifies for a categorical exclusion from environmental reviewpursuant to the provisions of 10 CFR 51.22(c)(9). Additionally, in accordance with 10 CFR50.91 (b)(1), TVA is sending a copy of this letter and the enclosure to the Tennessee StateDepartment of Public Health.

TVA requests routine processing of this TS change by the NRC and that theimplementation of the revised TS be within 30 days of NRC approval.

U.S. Nuclear Regulatory CommissionJune 5, 2009

There are no regulatory commitments associated with this submittal. If you have anyquestions about this change, please contact Michael Brandon at 423-365-1824.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this5th day of June, 2009.

Sincerely,

Mikeagqg 4Site Vice Presidednr~-Watts Bar Nuclear Plant

Enclosurecc: See Page 3

Enclosure: Evaluation of Proposed Change

U.S. Nuclear Regulatory CommissionJune 5, 2009

Enclosurecc (Enclosure):

NRC Resident InspectorWatts Bar Nuclear Plant1260 Nuclear Plant RoadSpring City, Tennessee 37381

U.S. Nuclear Regulatory CommissionMr. John G. Lamb, Senior Project ManagerDivision of Operating Reactor LicensingOffice of Nuclear Reactor RegulationMS 0-8 HIAWashington, DC 20555-0001

U.S. Nuclear Regulatory CommissionRegion IISam Nunn Atlanta Federal Center61 Forsyth St., SW, Suite 23T85Atlanta, Georgia 30303

Mr. Lawrence E. Nanny, DirectorDivision of Radiological Health3 rd Floor

L & C Annex401 Church StreetNashville, Tennessee 37243

ENCLOSURE1

TENNESSEE VALLEY AUTHORITY (TVA)WATTS BAR NUCLEAR PLANT

UNIT 1 WBN-TS-09-10OPERATING LICENSE NPF-90

EVALUATION OF THE PROPOSED CHANGE

SUBJECT: TECHNICAL SPECIFICATION 3.3.2, "ENGINEERED SAFETY FEATUREACTUATION SYSTEM (ESFAS) INSTRUMENTATION"

1.0 SUMMARY DESCRIPTION

This evaluation supports a request to amend Operating License NPF-90 for Watts Bar NuclearPlant (WBN), Unit 1. The proposed change will correct an error by changing a logic connectorfrom "OR" to "AND" between Required Actions 1.2.1 and 1.2.2 for TS 3.3.2, "ESFASInstrumentation," Condition I. This change will restore consistency with other similar TS actions.This error was apparently introduced during the development of the Unit 1 TSs prior to Unit 1Licensing.

2.0 DETAILED DESCRIPTION

This proposed amendment would change the logic connector from "OR" to "AND" betweenRequired Actions 1.2.1 and 1.2.2 of Condition I for TS 3.3.2 as indicated below:

CONDITION REQUIRED ACTION COMPLETION TIME

I. One Steam Generator Water 1.1 ----------- NOTE------Level--High High channel ----inoperable. One channel may be

bypassed for up to 12hours for surveillancetesting.

Insert "AND" -------------------- 72 hours

Delete "OR" ,Place channel in trip.78 hours

OR

1.2.1 Be in MODE 3.84 hours

OR

1.2.2 Be in MODE 4.

Attachment 1 to this enclosure provides the markup of the affected TS page. Attachment 2provides newly-typed version with the above change incorporated. The relevant TS and Basespages are provided in Attachment 3 as a review aid for this amendment.

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3.0 TECHNICAL EVALUATION

The WBN U1 TSs were developed in the early 1990s. They were based on early versions ofthe Westinghouse Owners Group (WOG) Standard Technical Specifications (STS)(NUREG 1431). In preparation for this amendment request, a review of the docketedcorrespondence was conducted. The following documents were found that documented theevolution of required actions 1.2.1 and 1.2.2 for Condition I:

1) NRC to TVA Letter dated April 2, 1993, requested TVA to review and comment on a "Proofand Review" version of the Unit 1 TSs. In that Proof and Review version, TS 3.3.2,Condition I had only two Required Actions, 1.1, "Place channel in trip." and 1.2, "Be in Mode3."

2) TVA to NRC Letter dated June 4, 1993 (ML073230460, ML073190382), providedcomments on the above "Proof and Review" version. In this submittal, TVA proposed amarkup to TS 3.3.2 which broke Required Action 1.2 into two separate Required Actions,1.2.1, "Be in Mode 3," and 1.2.2, "Be in Mode 4." The logic connector for these actions wasproposed to be "AND".

3) NRC to TVA Letter dated October 18, 1995 (ML073200588, ML073460315), transmittedthe photo-ready version of the U1 TSs. TS 3.3.2, Condition I in this version contained bothRequired Actions 1.2.1 and 1.2.2 but with the logic connector "OR".

4) NRC to TVA Letter dated November 9, 1995 (ML020780254), transmitted WBN's lowpower operating license which contained the issued TSs. TS 3.3.2, Condition I of thisversion also contained both Required Actions 1.2.1 and 1.2.2 with the logic connector being"OR".

Based on the results of this review, no reason could be found to explain what occurred to causethe incorporation of "OR" rather than "AND" between the proposed markup in Item 2 above andthe subsequent revision (Item 3) resulting in the final issue of the Ul TSs (Item 4). However, ifcompared with other similar actions of TS 3.3.2 (e.g., B.2.1 and B.2.2, C.2.1 and C.2.2, etc.)and in other TSs, one can see where the actions require the plant to change modes, thoseactions are connected with an "AND". Further justification for an "AND" connector can be foundin the following TS Bases sentence contained in initial November 1995 version which hasremained unchanged in the current version of the TS Bases (highlighted version of currentBases page B 3.3-108 is provided in Attachment 3):

"Failure to restore the inoperable channel to OPERABLE status or place it in the trippedcondition within 6 hours requires the plant to be placed in MODE 3 in 6 hours and inMODE 4 in the following 6 hours." (Emphasis added)

Based on the above, it can be concluded that the appropriate connector should be an "AND"between TS 3.3.2, Condition I, Actions 1.2.1 and 1.2.2.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

The regulatory bases and guidance documents associated with the ESFAS functions affectedby the proposed change includes: GDC-13 requires that instrumentation shall be provided to

El -2

monitor variables and systems over their anticipated ranges for normal operation, for anticipatedoperational occurrences; and for accident conditions as appropriate to assure adequate safety,including those variables and systems that can affect the fission process, the integrity of thereactor core, the reactor coolant pressure boundary, and the containment and its associatedsystems.

GDC-20 requires that the protection system shall be designed (1) to initiate automatically theoperation of appropriate systems including the reactivity control systems, to assure thatspecified acceptable fuel design limits are not exceeded as a result of anticipated operationaloccurrences and (2) to sense accident conditions and to initiate the operation of systems andcomponents important to safety.

GDC-21 requires that the protection system(s) shall be designed for high functional reliabilityand testability. GDC-22 through GDC-25 and GDC-29 require various design attributes for theprotection system, including independence, safe failure modes, separation from controlsystems, requirements for reactivity control malfunctions, and protection against anticipatedoperational occurrences.

Implementation of this proposed change will not compromise compliance with the requirementsof these documents. Based on the considerations discussed above, (1) there is reasonableassurance that the health and safety of the public will not be endangered by operation in theproposed manner, (2) such activities will be conducted in compliance with the Commission'sregulations, and (3) issuance of the amendment will not be inimical to the common defense andsecurity or to the health and safety of the public.

4.2 Precedent

WBN TS 3.3.2, Condition I is associated with Function 5.b in Table 3.3.2-1 and is applicable inModes 1-3 (for reviewer convenience, Page 3 of 7 of WBN Table 3.3.2-1 is provided inAttachment 3). Function 5.b in WOG STS Table 3.3.2-1, page 6 of 8 (also provided inAttachment 3) directs one to Condition D (if applicable in Modes 1-3 which would apply toWBN). Upon review of Condition D of the WOG STS, one can find that Condition D would bethe same as Condition I upon correction as proposed by this amendment.

In addition, a limited search of the NRC ADAMS Website was conducted but did not reveal anyprevious precedent involving "OR" and "AND" that would be comparable to this change.

4.3 Significant Hazards Consideration

TVA is requesting to amend Operating License NPF-90 for WBN Unit 1. The proposed changewill correct an error by changing a logic connector from "OR" to "AND" between RequiredActions 1.2.1 and 1.2.2 for TS 3.3.2, Condition I. This change will restore consistency with othersimilar TS actions. This error was apparently introduced during the development of the Unit 1TSs prior to Unit 1 Licensing.

TVA has evaluated whether or not a significant hazards consideration is involved with theproposed amendment-by focusing on the three standards set forth in 10 CFR 50.92, "Issuanceof Amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response: No.

E1-3

This proposed amendment corrects an identified error by only changing a logic connectorbetween two TS actions. The change only restores the sequential nature of theserequired actions consistent with other similar TS actions where, if conditions warrant, themovement of the plant to lower modes is required (i.e., to Mode 3, to Mode 4, etc.). Inaddition, this change does not alter the completion times for these actions. Therefore, theproposed change does not involve a significant increase in the probability orconsequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident

from any accident previously evaluated?

Response: No.

By correcting the logic connector between these two TS actions, this change only restoresconsistency with other similar TS actions where movement of the plant to lower modes isrequired. The change does not alter the expected outcome of the required actions nordoes it change the completion times for these actions. Therefore, the possibility of a newor different kind of accident from those previously analyzed has not been created.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

By only correcting the logic connector between the required actions, the proposed changedoes not alter the expected outcome of the required actions nor does it change thecompletion times for these actions. Therefore, the proposed change does not involve asignificant reduction in a margin of safety.

4.4 Conclusions

Based on the above, TVA concludes that the proposed amendment(s) present no significanthazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, afinding of "no significant hazards consideration" is justified. In addition, based on theconsiderations discussed above, (1) there is reasonable assurance that the health and safety ofthe public will not be endangered by operation in the proposed manner, (2) such activities willbe conduced in compliance with the Commission's regulations, and (3) the issuance of theamendment will not be inimical to the common defense and security or to the health and safetyof the public.

5.0 ENVIRONMENTAL EVALUATION

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

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6.0 REFERENCES

a) NRC to TVA Letter dated April 2, 1993 - 'Watts Bar Unit 1 - Proof and ReviewVersion of Technical Specification (TAC M76742)" (A02930408003)

b) TVA to NRC Letter dated June 4, 1993 - 'Watts Bar Nuclear Plant (WBN) Unit 1Technical Specifications - Comments on the Proof and Review" (ML073230460,ML073190382) (T04930604908)

c) TVA to NRC Letter dated October 18, 1995 - 'Watts Bar Nuclear Plant (WBN) -.Photo-Ready Version of the WBN Unit 1 Technical Specifications" (ML073200588,ML073460315) (T04951027241)

d) NRC to TVA Letter dated November 9, 1995 - "Issuance of Facility OperatingLicense NPF-20, Watts Bar Nuclear Plant, Unit 1 (TAC M91489)" (ML020780254)(L44951115002)

E1-5

ATTACHMENT 1

TENNESSEE VALLEY AUTHORITYWATTS BAR NUCLEAR PLANT (WBN)

UNIT I TS-09-10

PROPOSED TS CHANGES (MARKED-UP)

AFFECTED PAGE LIST

3.3-28

MARKED PAGES

See aftached.

ESFAS Instrumentation3.3.2

ACTIONS (continued)


1. One Steam Generator Water 1.1 -- NOTE --------Level--High High channel One channel may be bypassedinoperable, for up to 12 hours for

surveillance testing.

Place channel in trip. 72 hours

OR

Delete "OR" 1.2.1 Be in MODE 3. 78 hours

1.2.2 Be in MODE 4. 84 hours

J. One Main Feedwater JA Restore channel to 48 hoursPumps trip channel inoperable. OPERABLE status.

Ilnsert "AND", .--

J.2 Be in MODE 3. 54 hours

K. One channel inoperable. K.1 ---------- NOTE --------One channel may be bypassedfor up to 12 hours forsurveillance testing.

Place channel in bypass. 72 hours

OR

(continued)

Watts Bar-Unit 1 3.3-28 Amendment 68

ATTACHMENT 2


UNIT I TS-09-10

PROPOSED TS CHANGES (RETYPED PAGES)

AFFECTED PAGE LIST

3.3-28

MARKED PAGES

See attached.


ACTIONS (continued)


1. One Steam Generator Water 1.1 - --------- NOTE --------Level--High High channel One channel may be bypassedinoperable, for up to 12 hours for

surveillance testing.

Place channel in trip. 72 hours

OR


AND


J. One Main Feedwater J.1 Restore channel to 48 hours

Pumps trip channel inoperable. OPERABLE status.

OR

J.2 Be in MODE 3. 54 hours

K. One channel inoperable. K.1 ------------ NOTE--------One channel may be bypassedfor up to 12 hours forsurveillance testing.

Place channel in bypass. 72 hours

OR

___________________________(continued)

Wafts Bar-Unit 1 3.3-28 Amendment 68, __

ATTACHMENT 3


UNIT 1 TS-09-10

RELEVANT TS AND BASES PAGES

(INFORMATION ONLY)

I. AFFECTED PAGE LIST

WBN TS Page 3.3-36, Page 3 of 7WOG STS Page 3.3.2-14, Page 6 of 8WOG STS Page 3.3.2-2WOG STS Page 3.3.2-3WBN TS Bases Page B 3.3-108

II. MARKED PAGES

No Change - Relevant areas are highlighted. These pages submitted only as a reviewaid.


Table 3.3.2-1 (page 3 of 7)Engineered Safety Feature Actuation System Instrumentation

APPLICABLE MODES NOMINALOR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP

FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

4. Steam Line Isolation(continued)

c. Containment 1, 2 (c), 3 (c) 4 E SR 3.3.2.1 •2.9 psig 2.8 psigPressure- SR 3.3.2.4High High SR 3.3.2.9

SR 3.3.2.10

d. Steam LinePressure

(1) Low 1, 2 (c), 3 (a) (c) 3 per steam D SR 3.3.2.1 > 666.6(b) psig 6 7 5 (b) psigline SR 3.3.2.4

SR 3.3.2.9SR .3.2.10

(2) Negative 3 (d)(c) 3 per steam D SR 3.3.2.1 _ 108.5 () psi 10 0 c) psiRate-High line SR 3.3.2.4

SR 3.3.2.9SR 3.3.2.10

5. Turbine Trip andFeedwater Isolation

a. Automatic 1, 2(M, 3'(f 2 trains H SR 3.3.2.2 NA NAActuation Logic SR 3.3.2.3and Actuation SR 3.3.2.5Relays

b. SG Water 1, 2(0, 3(f) 3 per SG I SR 3.3.2.1 < 83.1% 82.4%Level-High SR 3.3.2.4High(P-14) SR 3.3.2.9

SR 3.3.2. 10

c. Safety Refer to Function I (Safety Injection) for all initiationInjection functions and requirements.

(continued)(a)(b)(c)(d)

(e)(f)

(g)(h)

Above the P-1 1 (Pressurizer Pressure) interlock.Time constants used in the lead/lag controller are t, > 50 seconds and t2 - 5 seconds.Except when all MSIVs are closed and de-activated.Function automatically blocked above P-1I1 (Pressurizer Interlock) setpoint and is enabled below P-1 I whensafety injection on Steam Line Pressure Low is manually blocked.Time constants utilized in the rate/lag controller are t3 and t4 - 50 seconds.Except when all MFIVs, MFRVs, and associated bypass valves are closed and de-activated or isolated by aclosed manual valve.MODE 2 if Turbine Driven Main Feed Pumps are operating.For the time period between February 23, 2000, and prior to turbine restart (following the next time the turbineis removed from service), the response time test requirement of SR 3.3.2.10 is not applicable for 1-FSV-47-027.

Watts Bar-Unit 1 3.3-36 Amendment 23


Table 3.3.2-1 (page 6 of 8)Engineered Safety Feature Actuation System Instrumentation

APPLICABLE MODESOR OTHER NOMINALO)SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP

FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

4. Steam Line Isolation

h. High High Steam 1,2 (h),3 (h) 2 per D SR 3.3.2.1 5 [130]% of full [ of full steamFlow steam line SR 3.3.2.5 steam flow at full flow at full

SR 3.3.2.9 load steam load steamSR 3.3.2.10 pressure pressure

Coincident with Refer to Function 1 (Safety Injection) for all initiation functions and requirements.Safety Injection

5. Turbine Trip andFeedwater Isolation

a. Automatic 1, 2 (i), [3](i) 2 trains H[G] SR 3.3.2.2 NA NAActuation Logic SR 3.3.2.4and Actuation SR 3.3.2.6

Relays

b. SG Water Level - 1,2 (i),[3 ](1) [3] per SG I[D] SR 3.3.2.1 < (84.2]% [82.4]%High High (P-14) SR 3.3.2.5

SR 3.3.2.9SR 3.3.2.10

c. Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

6. Auxiliary Feedwater

a. Automatic 1,2,3 2 trains G SR 3.3.2.2 NA NAActuation Logic SR 3.3.2.4and Actuation SR 3.3.2.6

Relays (SolidState ProtectionSystem)

b. Automatic 1,2,3 2 trains G SR 3.3.2.3 NA NAActuation Logicand ActuationRelays (Balanceof Plant ESFAS)

(h) Except when all MSIVs are closed and [de-activated].

(i) Except when all MFIVs, MFRVs, [and associated bypass valves] are closed and [de-activated] [or isolated by aclosed manual valve].

----------------.-------...........------------------------..... .--- REVIEWER'S NOTE -.-------.......-----------------------------------..(j) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by

the unit.

WOG STS 3.3.2-14 Rev. 3.0, 03/31/04


ACTIONS (continued)


C. One train inoperable. --------------- NOTE ---------One train may be bypassed for upto [4] hours for surveillance testingprovided the other train isOPERABLE.

C.1 Restore train to 24 hours

OPERABLE status.

OR

C.2.1 Be in MODE 3. 30 hours

AND

C.2.2 Be in MODE 5. 60 hours

D. One channel inoperable. [ -- ......-----The inoperable channel may bebypassed for up to 12 hours forsurveillance testing of otherchannels.

----.----- REVIEWER'S NOTE---------The below Note should be used forplants with installed bypass testcapability:

One channel may be bypassed forup to 12 hours for surveillancetesting.---------------------------------------

D.1 Place channel in trip. 72 hours

OR

WOG STS 3.3.2-2 Rev. 3.0, 03/31/04


ACTIONS (continued)


D.2.1 Be in MODE 3. 78 hours

AND

D.2.2 Be in MODE 4. 84 hours

E. One Containment [ -------- NOTE ---------Pressure channel One additional channel may beinoperable, bypassed for up to 12 hours for

surveillance testing of otherchannels.

---------- REVIEWER'S NOTE ----------The below Note should be used forplants with installed bypass testcapability.

One channel may be bypassed forup to 12 hours for surveillancetesting.---- -------------------------------------

E.1 Place channel in bypass. 72 hours

OR

E.2.1 Be in MODE 3. 78 hours

AND

E.2.2 Be in MODE 4. 84 hours

F. One channel or train F.1 Restore channel or train to 48 hours

inoperable. OPERABLE status.

OR

F.2.1 Be in MODE 3. 54 hours

AND

WOG STS 3.3.2-3 Rev. 3.0, 03/31/04

ESFAS InstrumentationB 3.3.2

BASES

ACTIONS H.1, H.2.1 and H.2.2 (continued)

assumption that 4 hours is the average time required to perform channelsurveillance.

1.1. 1.2.1 and 1.2.2

Condition I applies to SG Water Level-High High (P-14).

If one channel is inoperable, 72 hours are allowed to restore one channel toOPERABLE status or to place it in the tripped condition. If placed in the trippedcondition, the Function is then in a partial trip condition where one-out-of-twologic will result in actuation. The 72 hours allowed to restore the channel toOPERABLE status or to place it in the tripped condition are justified in Reference17. Failure to restore the inoperable channel to OPERABLE status or place it inthe tripped condition within 72 hours requires the plant to be placed in MODE 3in 6 hours and in MODE 4 in the following 6 hours. The allowed CompletionTimes are reasonable, based on operating experience, to reach MODE 4 fromfull power conditions in an orderly manner and without challenging plant systems.In MODE 4, these Functions are no longer required OPERABLE.

The Required Actions have been modified by a Note that allows placing aninoperable channel in bypassed condition for up to 12 hours while performingroutine surveillance testing of other channels. The Note also allows a channel tobe placed in bypass for up to 12 hours for testing of the bypassed channel.However, only one channel may be placed in bypass at any one time. The 12hours allowed for testing are justified by Reference 17.

J.1 and J.2

Condition J applies to the AFW pump start on trip of all MFW pumps.

The OPERABILITY of the AFW System must be assured by allowing automaticstart of the AFW System pumps. If a channel is inoperable, 48 hours are allowedto return it to an OPERABLE status. If the function cannot be returned to an

(continued)

Watts Bar-Unit 1 B 3.3-108 Revision 90Amendment 68

watts bar - unit 1 - technical specification change 09-10 - … · atlanta, georgia 30303 mr....

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