\ I I Jon A. Franke Site Vice President PPL Susquehanna, LLC ' ' 1 I ' 769 Salem Boulevard '' \ • 1 1 / •••••• # , ====== - • ... - Berwick, PA 18603 • I • *' jfmnk,@pplw,b.com pp U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT NUMBER 314 TO UNIT 1 OPERATING LICENSE NO. NPF-14 PROPOSED AMENDMENT NUMBER 286 TO UNIT 2 OPERATING LICENSE NO. NPF-22 CHANGE TO ALLOW ONLY ONE MANUAL TRIP SYSTEM TO BE OPERABLE FOR THE RHR SHUTDOWN COOLING SYSTEM IN MODES 4 AND 5 FOR UNIT 1 AND UNIT 2 TECHNICAL SPECIFICATION 3.3.6.1 PLA-6990 Docket No. 50-387 and No. 50-388 Pursuant to 10 CFR 50.90, PPL Susquehanna, LLC (PPL), hereby requests approval of the following proposed amendment to the Susquehanna Steam Electric Station (SSES) Unit 1 and Unit 2 Technical Specifications (TS). The proposal would change Technical Specification 3.3.6.1 "Instrumentation - Primary Containment Isolation Instrumentation" in both Units' Technical Specifications. This proposed change adds a footnote to Function 6c in Technical Specification Table 3.3 .6.1-1. This change allows only one Trip System to be operable in MODES 4 and 5 for the Manual Initiation Function for Shutdown Cooling System isolation. As demonstrated in the enclosed evaluation, the proposed amendment does not involve a significant hazard consideration. PPL requests that this change be approved by March 1, 2014. PPL further requests that the approved amendment be issued to be effective immediately upon approval with the implementation to be completed within 30 days. The Enclosure to this letter provides the Evaluation of the Proposed Changes to Unit 1 and Unit 2 Technical Specification 3.3 .6.1. Attachment 1 is the Technical Specifications mark-up. Attachment 2 is a mark-up of the associated Technical Specification Bases changes provided for information. There are no regulatory commitments associated with the proposed changes. ' TM
Transcript
\ I I
Jon A. Franke Site Vice President
PPL Susquehanna, LLC ' ' 1 I ' 769 Salem Boulevard ' ' \ •
1 1 / ~ ~ •••••• # ,
======-<J"<ei~/0~5<tL.290~rax570-:-5<t2-:-rsoLt ====== - • ... -Berwick, PA 18603 • I • *'
jfmnk,@pplw,b.com p p .~:: ~
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUSQUEHANNA STEAM ELECTRIC STATION PROPOSED AMENDMENT NUMBER 314 TO UNIT 1 OPERATING LICENSE NO. NPF-14 PROPOSED AMENDMENT NUMBER 286 TO UNIT 2 OPERATING LICENSE NO. NPF-22 CHANGE TO ALLOW ONLY ONE MANUAL TRIP SYSTEM TO BE OPERABLE FOR THE RHR SHUTDOWN COOLING SYSTEM IN MODES 4 AND 5 FOR UNIT 1 AND UNIT 2 TECHNICAL SPECIFICATION 3.3.6.1 PLA-6990
Docket No. 50-387 and No. 50-388
Pursuant to 10 CFR 50.90, PPL Susquehanna, LLC (PPL), hereby requests approval of the following proposed amendment to the Susquehanna Steam Electric Station (SSES) Unit 1 and Unit 2 Technical Specifications (TS). The proposal would change Technical Specification 3.3.6.1 "Instrumentation - Primary Containment Isolation Instrumentation" in both Units' Technical Specifications.
This proposed change adds a footnote to Function 6c in Technical Specification Table 3.3 .6.1-1. This change allows only one Trip System to be operable in MODES 4 and 5 for the Manual Initiation Function for Shutdown Cooling System isolation.
As demonstrated in the enclosed evaluation, the proposed amendment does not involve a significant hazard consideration.
PPL requests that this change be approved by March 1, 2014. PPL further requests that the approved amendment be issued to be effective immediately upon approval with the implementation to be completed within 30 days.
The Enclosure to this letter provides the Evaluation of the Proposed Changes to Unit 1 and Unit 2 Technical Specification 3.3 .6.1. Attachment 1 is the Technical Specifications mark-up. Attachment 2 is a mark-up of the associated Technical Specification Bases changes provided for information.
There are no regulatory commitments associated with the proposed changes.
' TM
- 2- Document Control Desk PLA-6990
The need for this change has been discussed with the SSES NRC Project Manager, and it has also been reviewed by the S SES Plant Operations Review Committee and by the Susquehanna Review Committee.
In accordance with 10 CFR 50.91(b), PPL Susquehanna, LLC is providing the Commonwealth of Pennsylvania with a copy of this proposed License Amendment request.
If you have any questions or require additional information, please contact Mr. Duane L. Filchner (610) 774-7819.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on:
Sincerely,
Enclosure: PPL Susquehanna, LLC Evaluation of Proposed Changes to Unit 1 and Unit 2 Technical Specification 3.3 .6.1 "Instrumentation- Primary Containment Isolation Instrumentation"
Attachment 1 Proposed Changes to Unit 1 and Unit 2 Technical Specification 3.3.6.1 "Instrumentation - Primary Containment Isolation Instrumentation" (Mark-ups)
Attachment 2 Proposed Change to Unit 1 and Unit 2 Technical Specifications Bases 3.3.6.1 "Instrumentation- Primary Containment Isolation Instrumentation" (Mark -ups provided for Information Only)
Copy: NRC Region I Mr. P. W. Finney, NRC Sr. Resident Inspector Mr. J. A. Whited, NRC Project Manager Mr. L. J. Winker, PA DEP/BRP
Enclosure to PLA-6990
PPL Susquehanna, LLC Evaluation of Proposed Changes to
Unit 1 and Unit 2 Technical Specification 3.3.6.1 ''Instrumentation - Primary Containment
Isolation Instrumentation''
1. DESCRIPTION
2. PROPOSED CHANGE
3. BACKGROUND
4. TECHNICAL ANALYSIS
5. REGULATORY SAFETY ANALYSIS
5.1 No Significant Hazards Consideration
5.2 Applicable Regulatory Requirements/Criteria
6. ENVIRONMENTAL CONSIDERATIONS
7. REFERENCES
PPL EVALUATION
Enclosure to PLA-6990 Page 1 of6
Subject: PPL Susquehanna Evaluation of Proposed Changes to Unit 1 and Unit 2 Technical Specification 3.3.6.1- Instrumentation- Primary Containment Isolation Instrumentation"
1. DESCRIPTION
The proposed change to the PPL Susquehanna (PPL) Unit 1 and Unit 2 Technical Specification 3.3.6.1 reflects a change to the required number of Trip Systems for the Manual Isolation Function for the RHR Shutdown Cooling System MODES 4 and 5. This change will allow continued operation of the RHR Shutdown Cooling System when one Trip System is inoperable. The change is also consistent with the operable Trip Systems for other Shutdown Cooling isolation functions for MODES 4 and 5.
2. PROPOSED CHANGE
6.
(c)
A mark-up of the proposed changes to the Unit 1 and Unit 2 Technical Specifications (TS) 3.3.6.1 is included in Attachment 1 of this submittal. Function 6c in Unit 1 and Unit 2 TS Table 3.3.6.1-1 is revised to add a footnote which allows only one trip system to be operable for the Manual Isolation Function in MODES 4 and 5. Function 6c is revised as follows:
Shutdown Cooling System Isolation
a. Reactor Steam Dome 1 ,2,3 F SR 3.3.6.1.2 ::::; 108 psig Pressure- High SR 3.3.6.1 .3
SR 3.3.6.1.5
b. Reactor Vessel Water 3,4,5 2(c)
J SR 3.3.6.1 .1 ~ 11.5 inches Level- Low, Level 3 SR 3.3.6.1 .2
SR 3.3.6.1 .3 SR 3.3.6.1 .5
c. Manual Initiation 3,4,5 1.(_g} G SR 3.3.6.1.5 NA
Only one trip system required in MODES 4 and 5 when RHR Shutdown Cooling System integrity maintained.
The Unit 1 and Unit 2 TS Bases Section B 3.3 .6.1 have also been revised based on this change.
3. BACKGROUND
Enclosure to PLA-6990 Page 2 of6
The proposed change is necessary in order not to isolate RHR Shutdown Cooling System in MODES 4 and 5 should a manual isolation Trip System be inoperable and the integrity of the RHR Shutdown Cooling System is intact. RHR Shutdown Cooling primarily operates in MODES 4 and 5. With the loss of a manual isolation Trip System, the alternate shutdown path using SRVs and the Core Spray System would have to be implemented. The change would allow maintenance on a Trip System or power supply without isolating RHR Shutdown Cooling.
4. TECHNICAL ANALYSIS
The Standard Technical Specifications (NUREG-1433) (STS) allows the automatic isolation function (Reactor Vessel Water Level Low, Level3) for the Shutdown Cooling System to have only one required trip system operable provided the RHR Shutdown Cooling System integrity is maintained in MODES 4 and 5 in accordance with Footnote (c) of Table 3.3.6.1-1. Therefore, the loss of one trip system would not require the shutdown and isolation of the RHR Shutdown Cooling System in MODES 4 and 5 when the system is needed to be operable in order to maintain temperature in the reactor vessel.
The design of the manual initiation function for the RHR Shutdown Cooling System Isolation are two trip systems each consisting of a push button which introduce signals to the isolation logic for each of the isolation valves. There is no specific FSAR safety analysis that takes credit for this function. In addition, Reactor Vessel Water Level- Low, Level 3 automatic isolation function is not directly assumed in safety analysis because a break of the RHR Shutdown Cooling System is bounded by breaks in the recirculation system and the main steam lines.
The manual isolation function of the RHR Shutdown Cooling is not a required function in the STS. During the conversion to STS this function was added to the listing of the primary containment isolation instrumentation in Technical Specification Table 3.3.6.1-1 in both units. The addition of this function was justified as a change needed to ensure that the S TS account for the design and/ or the design is accurately and completely described in the bases. At the time of the conversion, Footnote (c) was applicable to the manual isolation function and should have been applied.
The addition ofF ootnote (c) to the manual isolation function will eliminate an unnecessary isolation of the Shutdown Cooling System in the MODES when the system is needed to maintain reactor vessel water temperature should one trip system become inoperable. The addition of the footnote would make the requirements for the RHR Shutdown Cooling System isolation consistent.
5. REGULATORY SAFETY ANALYSIS
5.1 No Significant Hazards Consideration
Enclosure to PLA -6990 Page 3 of6
This "No Significant Hazards Consideration" evaluates the addition of Footnote (c) to Function 6c in Technical Specification Table 3.3.6.1-1 to allow one manual isolation Trip System to be inoperable in MODES 4 and 5.
1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No
The manual isolation function of the RHR Shutdown Cooling System is not credited in any FSAR safety analysis. The addition ofF ootnote (c) to the manual isolation function in TS Table 3.3.6.1-1 allows one of the two trip systems to be inoperable in MODES 4 and 5 and does not alter any equipment.
Therefore, this proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No
The addition of Footnote (c) to the manual isolation function in TS Table 3.3.6.1-1 allows one of the two trip systems to be inoperable in MODES 4 and 5 and is consistent with other isolation function required for isolation in MODES 4 and 5.
No new equipment is being introduced, and installed equipment is not being operated in a new or different manner. There are no setpoints, at which protective or mitigative actions are initiated, affected by this change. These changes do not alter the manner in which equipment operation is initiated, nor will the function demands on credited equipment be changed. No alterations in the procedures that ensure the plant remains within analyzed limits are being proposed, and no major changes are being made to the procedures relied upon to respond to an off-normal event as described in the FSAR. As such, no new failure modes are being introduced. The proposed change does not alter assumptions made in the safety analysis and licensing basis since the manual isolation function of the RHR Shutdown Cooling System is not credited in any FSAR safety analysis.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
Enclosure to PLA-6990 Page 4 of6
3. Do the proposed changes involve a significant reduction in a margin of safety?
Response: No
The margin of safety is established through equipment design, operating parameters, and the setpoints at which automatic actions are initiated. The proposed changes are acceptable since no automatic isolation functions are being changed. Since the manual isolation function of the RHR Shutdown Cooling System is not credited in any FSAR safety analysis, this change does not affect the margin of safety assumed by the safety analysis.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, PPL concludes that the proposed changes do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92( c), and accordingly, a fmding of no significant hazards consideration is justified.
5.2 Applicable Regulatory Requirements/Criteria
SSES FSAR Sections 3.1 and 3.13 provide detailed discussion ofSSES compliance with the applicable regulatory requirements and guidance.
The proposed TS amendment:
(a) Does not result in any change in the qualifications of any component; and
(b) Does not result in the reclassification of any component's status in the areas of shared, safety-related, independent, redundant, and physically or electrically separated.
Susquehanna conformance with the applicable General Design Criteria (GDC) related to the proposed Unit 1 and Unit 2 TS 3.3 .6.1 change is provided as follows:
GDC 34- Residual Heat Removal System
RHR system provides the means to remove decay heat and residual heat from the nuclear system so that refueling and nuclear system servicing can be performed. Additional details are provided in FSAR Section 5.4.
The reactor coolant pressure boundary (as defined in 10CFR50, Section 50.2) consists of the reactor pressure vessel, pressure retaining appurtenances attached to the vessel, valves and pipes which extend from the reactor pressure vessel up to and including the outermost containment isolation valve. The lines of the reactor coolant pressure boundary which penetrate the containment have suitable isolation valves capable of isolating the containment thereby precluding any significant release of radioactivity. Similarly for lines which do not penetrate the containment but which form a portion of the reactor coolant pressure boundary, the design ensures that isolation of the reactor coolant pressure boundary can be achieved.
Additional discussion and details are provided in FSAR Section 6.2.
Based on compliance with the General Design Criteria 34 and 55 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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
6. ENVIRONMENTAL CONSIDERATION
10 CFR 51.22( c )(9) identifies certain licensing and regulatory actions, which are eligible for categorical exclusion from the requirement to perform an environmental assessment. A proposed amendment to an operating license for a facility does not require an environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or (3) result in a significant increase in individual or cumulative occupational radiation exposure. PPL Susquehanna, LLC has evaluated the proposed change and has determined that the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22( c )(9). Accordingly, pursuant to 1 0 CFR 51.22(b ), no environmental impact statement or environmental assessment needs to be prepared in connection with issuance of the amendment. The basis for this determination, using the above criteria, follows:
As demonstrated in the "No Significant Hazards Consideration" evaluation, the proposed amendment does not involve a significant hazards consideration.
Enclosure to PLA -6990 Page 6 of6
There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite. The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.
There is no significant increase in individual or cumulative occupational radiation exposure. The proposed change does not involve any physical alteration of the plant (no new or different type of equipment will be installed) or change in methods governing normal plant operation.
7. REFERENCES
FSAR Sections 3.1, 3.13, 6.2, and 5.4
Attachment 1 to PLA-6990
PPL Susquehanna, LLC
Proposed Changes to Unit 1 and Unit 2 Technical Specification 3.3.6.1
6.b. Reactor Vessel Water Level-Low, Level 3 (continued)
In MODES 1 and 2, another isolation (i.e., Reactor Steam Dome Pressure-High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path.
6.c Manual Initiation
The Manual Initiation push button channels introduce signals to RHR Shutdown Cooling System isolation logic that is redundant to the automatic protective instrumentation and provide manual isolation capability. There is no specific FSAR safety analysis that takes credit for this Function. It is retained for overall redundancy and diversity of the isolation function as required by the NRC in the plant licensing basis.
There are two push buttons for the logic, one manual initiation push button per trip system. There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.
Two channels of the Manual Initiation Function are available and are required to be OPERABLE in MODES 3, 4, and 5, since these are the MODES in which the RHR Shutdown Cooling System Isolation automatic Function are required to be OPERABLE.
As noted (footnote (c) to Table 3.3.6.1-1 ), only one channel of the Manual Initiation Function is required to be OPERABLE in MODES 4 and 5 provided the RHR Shutdown Cooling System integrity is maintained. System integrity is maintained provided the piping is intact and no maintenance is being performed that has the potential for draining the reactor vessel through the system.
Traversing lncore Probe System Isolation
7.a Reactor Vessel Water Level- Low. Level 3
Low RPV water level indicates that the capability to cool the fuel may be threatened. The valves whose penetrations communicate with the primary containment are isolated to limit the release of fission products. The isolation of the primary containment on Level 3 supports actions to ensure that offsite and control room dose regulatory limits are not exceeded. The Reactor Vessel Water Level- Low, Level 3 Function associated with isolation is implicitly assumed in the FSAR analysis as these leakage paths are assumed to be isolated post LOCA.
I SUSQUEHANNA- UNIT 1 TS I B 3.3-170 Revision ~
APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY
6.b. Reactor Vessel Water Level-Low. Level 3 (continued)
In MODES 1 and 2, another isolation (i.e., Reactor Steam Dome Pressure-High) and administrative controls ensure that this flow path remains isolated to prevent unexpected loss of inventory via this flow path.
6.c Manual Initiation
The Manual Initiation push button channels introduce signals to RHR Shutdown Cooling System isolation logic that is redundant to the automatic protective instrumentation and provide manual isolation capability. There is no specific FSAR safety analysis that takes credit for this Function. It is retained for overall redundancy and diversity of the isolation function as required by the NRC in the plant licensing basis.
There are two push buttons for the logic, one manual initiation push button per trip system. There is no Allowable Value for this Function since the channels are mechanically actuated based solely on the position of the push buttons.
Two channels of the Manual Initiation Function are available and are required to be OPERABLE in MODES 3, 4, and 5, since these are the MODES in which the RHR Shutdown Cooling System Isolation automatic Function are required to be OPERABLE.
As noted (footnote (c) to Table 3.3.6.1-1). only one channel of the Manual Initiation Function is required to be OPERABLE in MODES 4 and 5 provided the RHR Shutdown Cooling System integrity is maintained. System integrity is maintained provided the piping is intact and no maintenance is being performed that has the potential for draining the reactor vessel through the system.
Traversing lncore Probe System Isolation
7.a Reactor Vessel Water Level- Low. Level 3
Low RPV water level indicates that the capability to cool the fuel may be threatened. The valves whose penetrations communicate with the primary containment are isolated to limit the release of fission products. The isolation of the primary containment on Level 3 supports actions to ensure that offsite and control room dose regulatory limits are not exceeded. The Reactor Vessel Water Level - Low, Level 3 Function associated with isolation is implicitly assumed in the FSAR analysis as these leakage paths are assumed to be isolated post LOCA.
