Watts Bar Nuclear Plant (Wbn) - Unit 1 - Technical Specification (Ts) Change Ts-03-16, "Revision of Ultimate Heat Sink (Uhs) Temperature"
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Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 William R. Lagergren, Jr. Site Vice President, Watts Bar Nuclear Plant APR 0 7 2004 TVA-WBN-TS-03-16 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen: In the Matter of ) Docket No. 50-390 Tennessee Valley Authority ) WATTS BAR NUCLEAR PLANT (WBN) - UNIT 1 - TECHNICAL SPECIFICATION (TS) CHANGE TS-03-16, "REVISION OF ULTIMATE HEAT SINK (UHS) TEMPERATURE" Pursuant to 10 CFR 50.90, TVA is submitting a request for an amendment to WBN's License NPF-90 to change the Technical Specifications for Unit 1. The proposed TS change (TS 03-16) will revise the limiting condition for operation for TS Section 3.7.9, "Ultimate Heat Sink." The maximum essential raw cooling water (ERCW) temperature limit associated with Surveillance Requirement (SR) 3.7.9.1 will be annotated with a note allowing an occasional increase from 85 degrees Fahrenheit (0F) to 880F. This proposed change is based on recent evaluations of the ERCW system and the UHS functions and maximum temperatures that will satisfy the associated safety functions. In addition, an administrative change is proposed to clarify the maximum allowable internal containment pressure. Corresponding TS Bases changes are also included for the temperature increase for UHS and the containment pressure clarification including a minor change in the maximum calculated containment pressure resulting from the increased UHS temperature. 1--~56 Pa0ted.]n ,Ededpa U.S. Nuclear Regulatory Commission Page 2 APR 0 7 2004 TVA discussed its plans for this proposal in a meeting with NRC staff in August 2003. -The meeting provided TVA the opportunity to describe the basis and key considerations for the UHS Temperature Increase evaluation. The discussion was beneficial for TVA's understanding of potential Staff questions and concerns; these items have been addressed herein. This request is similar to the approved license amendment request by Nebraska Public Power District, Cooper Nuclear Station, Amendment No. 193, issued July 22, 2002; Consumers Energy Company, Palisades Plant, Amendment No. 202, issued June 4, 2001; and Commonwealth Edison Company, Braidwood Station, Amendment Nos. 107 and 107 for Units 1 and 2, respectively, issued June 13, 2000. These requests proposed and received NRC approval for an increase in a single maximum UHS temperature limit. TVA has determined that there are no significant hazards considerations associated with the proposed change and that the TS change qualifies for categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9). Additionally, in accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and enclosures to the Tennessee State Department of Public Health. Enclosure 1 to this letter provides the description and evaluation of the proposed change. This includes TVA's determination that the proposed change does not involve a significant hazards consideration, and is exempt from environmental review. An Attachment to Enclosure 1 provides TVA's detailed Engineering Report for the subject proposal. Enclosures 2 and 3 contain copies of the applicable Unit 1 TS and TS Bases pages, respectively, marked-up to show the proposed changes. Enclosure 4 lists the commitments made for this submittal. The proposed change addresses temperature limits for the UHS function that have been challenged in late summer. Therefore, TVA requests approval of this amendment by August 1, 2004, and requests that implementation occur within 45 days of approval. U.S. Nuclear Regulatory Commission Page 3 APR 0 7 2004 If you have any questions about this change, please telephone P. L. Pace at (423) 365-1824. I declare under penalty of perjury that the foregoing is true and correct. Executed on this 7th day of April, 2004. Sincere y, W. R. agerg n Enclosures: 1. TVA Description and Evaluation of the Proposed Change Attachment - Engineering Report, "Ultimate Heat Sink - 88°F Maximum Operating Temperature Evaluation, Watts Bar Nuclear Plant, April 2, 2004, Revision 2" 2. Proposed Technical Specifications Changes (mark-up) 3. Proposed Technical Specifications Bases Changes (mark-up) 4. List of Commitments Enclosures cc: See Page 4 U.S. Nuclear Regulatory Commission Page4 - APR 0 7 200O cc (Enclosures): NRC Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 Ms. Margaret H. Chernoff, Project Manager U.S. Nuclear Regulatory Commission MS 08G9 One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. Lawrence E. Nanney, Director Division of Radiological Health Third Floor L&C Annex 401 Church Street Nashville, Tennessee 37243-1532 ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT (WBN) UNITS 1 DOCKET NO. 390 PROPOSED LICENSE AMENDMENT REQUEST WBN-TS-03-16 - REVISION OF ULTIMATE HEAT SINK (UHS) TEMPERATURE DESCRIPTION AND EVALUATION OF PROPOSED CHANGE 1.0 DESCRIPTION The purpose of this letter is to request an amendment to the Operating License NPF-90 and Technical Specifications (TS) for Watts Bar Nuclear Plant Unit 1. The proposed TS change will revise the limiting condition for operation (LCO) for TS Section 3.7.9, "Ultimate Heat Sink." The change will increase the maximum allowed essential raw cooling water (ERCW) temperature from 85 degrees Fahrenheit (0F) to 880F for Surveillance Requirement (SR) 3.7.9.1 for short durations due to seasonal variations. The proposed change is based on recent evaluations of the ERCW system and the UHS functions and maximum temperatures and minimum river elevations that will satisfy the associated safety functions. The proposed change satisfies TVA's intent to propose a permanent TS change that will reduce the challenges to the UHS limit. In addition, an administrative change is proposed to clarify the maximum allowable internal containment pressure. Corresponding TS Bases changes are included for the temperature increase for UHS and the containment pressure clarification including a minor change in the maximum calculated containment pressure resulting from the increased UHS temperature. 2.0 PROPOSED CHANGE The proposed change will revise WBN TS Section 3.7.9, "Ultimate Heat Sink," specifically, Surveillance Requirement (SR) 3.7.9.1. A footnote has been added to the SR which would allow an increase in the ERCW temperature limit from 850 F to 880 F for short durations due to seasonal variations. An administrative change is proposed to clarify the maximum allowable internal containment pressure consistent with the current TS Bases. Corresponding TS Bases changes are also proposed. The TS and TS Bases changes affect the following sections and are illustrated by marked-up pages provided in Enclosures 2 and 3: El-1 Technical Specification 1) SR 3.7.9.1 (Page 3.7-21) is revised to add the following footnote: "(*) UHS average water temperature > 850 F and < 880 F is acceptable for short durations due to seasonal variations.N 2) TS 5.7.2.19 (Page 5.0-28), second paragraph is revised from: "The peak calculated containment internal pressure for the design basis loss of coolant accident, Pa, is 15.0 psig.0 to: "The maximum allowable containment internal pressure, Pa, is 15.0 psig, which bounds the peak calculated containment internal pressure resulting from the design basis LOCA.L Technical Specification Bases Corresponding TS Bases changes are included for the temperature increase to 880 F for UHS. The TS Bases are also revised to reflect the revised peak containment pressure resulting from the containment pressure reanalysis using the increased ERCW temperature of 880 F, and to clarify the maximum allowable internal containment pressure. Refer to the markups provided in Enclosure 3. In particular, as discussed in Section 4 of this report, the proposed revisions to the TS Bases include a discussion of contingency measures considered prudent if UHS temperature should exceed 850 F. The following change is proposed: 5) Section B 3.7.9, SR 3.7.9.1 (Page B 3.7-50): Insert: "A note indicates UHS average water temperature > 85 0 F and <880 F is acceptable for short durations and is based on the engineering evaluation provided in Reference 4. If surveillance performance indicates the average water temperature of UHS will exceed 850 F, site procedures/documents require the following contingency actions: Perform an engineering evaluation and appropriate risk- management actions (1) To confirm UHS operability for existing ERCW equipment problems that would remain concurrent with UNS temperature above 85 0 F, and (2) Prior to initiating an elective work activity that would render an ERCW component required by LCO 3.7.8 inoperable. E1-2 These contingency measures are not required for UHS operability and are not credited in the safety analyses/evaluations of Reference 4. However, they are intended to minimize the impact of operation above 850F, since such operation may exceed the original design parameters for ERCW supplied components. Because margin above design has been utilized to validate such operation, the contingency measures are considered prudent to maintain defense-in-depth." 3.0 BACKGROUND AND SUMMARY On August 2, 2002, the UHS temperature at WBN approached the Technical Specification limit of 85'F. If this limit had been exceeded it could have resulted in an unnecessary unit shutdown to comply with Technical Specification LCO 3.7.9. Multipurpose river operation coupled with hotter than normal summers and below normal river flows has prompted resolution of this critical operating condition. Past efforts by TVA to address this condition have included temporary manipulation of the Tennessee River system, including upstream reservoirs, in order to maintain acceptable temperature in the Chickamauga Reservoir pool. These special operations can involve significant operating expenses and coordination difficulties with unpredictable results and limited success.