PLA-7125, Response to Request for Additional Information on Change to Technical Specification Surveillance Requirement 3.5.1.12
| ML14023A881 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 01/23/2014 |
| From: | Franke J Susquehanna |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| PLA-7125 | |
| Download: ML14023A881 (24) | |
Text
JAN 2 3 2014
.Jon A. Franke Site Vice President U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PPL Susquehanna, LLC 769 Salem Boulevard Berwick, PA 18603 TeL 570.542.2904 Fax 570.542.1504 jfranke@ pplweb.com SUSQUEHANNA STEAM ELECTRIC STATION RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION ON CHANGE TO TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT (SR) 3.5.1.12 PLA-7125 Docket No 50-387 and No. 50-388
References:
I. PPL Letter (PLA-6977), titled "Proposed Amendment No. 313 to License NPF-I4 and Proposed Amendment No. 285 to License NPF-22: Change to Technical Specification Surveillance Requirement (SR) 3.5.I.I2," dated June 06, 20I3.
- 2.
NRC Letter, titled "Susquehanna Steam Electric Station, Units I and 2 -Request for Additional Information Regarding Request for Changes to Technical Specification Surveillance Requirement 3.5.I.I2: (TAC Nos. MFI955 and MFI956),"
dated December I8, 2013.
The purpose of this letter is for PPL Susquehanna, LLC (PPL) to provide a response to the request for additional information contained in Reference 2. The NRC discussed a draft of the requested information with PPL on December 17, 2013, to ensure the questions were understood. PPL agreed to provide this response by January 24, 2014. The information supports a review of the proposed changes to Technical Specification (TS) Surveillance Requirement (SR) 3.5.1.12, for the Automatic Depressurization System valve actuators.
The requested information is in Attachment 1 to this letter. Attachments 2 and 3 contain the revised TS and TS Bases markups that reflect this additional information. Attachment 4 contains additional figures provided by the response.
PPL has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1.
The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
Document Control Desk PLA-7125 There are no regulatory commitments associated with this response.
If you have any questions or require additional information, please contact Mr. Richard W. Mcintosh (570) 542-1695.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on:
<e ' /l-~ / '2-D t 'f Sincerely, At chments: Response to Request for Additional Information Technical Specification Markups (Units 1 and 2) (Revised) Technical Specification Bases Markups (Units 1 and 2) (Revised) Drawings: P&ID M-141, Sheets 1, 2 and Assembly (selected sheets)
Copy:
NRC Region I Mr. J. Greives, NRC Sr. Resident Inspector Mr. J. Whited, NRC Project Manager Mr. L. Winker, PA DEP/BRP to PLA-7125 Response to Request for Additional Information to PLA-7125 Page 1 of 8 Response to Request for Additional Information The additional information provided by this attachment supports a review of proposed changes<I) to Technical Specification (TS), Surveillance Requirement (SR) 3.5.1.12, for the Automatic Depressurization System valve actuators. The NRC request<2) for additional information (RAI) includes questions from the Division of Safety Systems, Technical Specifications Branch (STSB), the Division of Engineering, Instrumentation and Controls Branch (EICB), and the Component Performance, Non-Destructive Examination (NDE), and Testing Branch (EPNB).
The PPL response to the RAI is provided below.
EICB RAI 1:
Provide a description of Susquehanna's operating experience with single and repeated open cycling action with the ADS [Automatic Depressurization System] valves that develop the leakage. The discussion would assist the staff in understanding and considering the problem being experienced.
PPL's RESPONSE:
Recent Operating Experience (OE) at the Susquehanna Steam Electric Station (SSES) is described in a Licensee Event Report (LER) 2013-002-00, "Valve Internal Misalignment Resulting in Multiple Inoperable Main Steam Safety Relief Valves," dated July 3, 2013 for Unit 2. Three Main Steam Safety Relief Valves (SRVs) failed to meet the setpoint criteria set forth in the Technical Specifications (TS). Cycling the valves with the actuator, prior to start-up, was observed to have led to misalignment of valve internals. Misalignment of load bearing parts resulted in the reduced lift setpoints. Recent OE is also described in LER 2012-005-00, "Valve Internal Misalignment Resulting in Multiple Inoperable Main Steam Safety Relief Valves," dated August 2, 2012, which describes two Main Steam SRVs' failure to meet the setpoint criteria set forth in TS. The cause of this condition was also misalignment of valve internals from cycling the valves with the actuator, prior to start-up.
Experience across the industry and at SSES has shown that manual actuation of SRVs during plant operation (start-up) can lead to valve seat leakage and other valve condition issues.
Industry OE shows how excessive seat leakage has caused premature opening of SRVs at other domestic BWRs using pilot operated valves. The ADS valves at SSES are Crosby, Dual Function SRVs, with Model Number HB-65-BP, Size 6R10. The ADS valves at SSES use a direct acting SRV that is less susceptible to inadvertent opening but this industry OE is applicable to SSES also, and leakage and valve cycling does contribute to lowering of the valve set pressure.
(I)
PPL Letter (PLA-6977), titled "Proposed Amendment No. 313 to License NPF-14 and Proposed Amendment No. 285 to License NPF-22: Change to Technical Specification Surveillance Requirement (SR) 3.5.1.12,"
dated June 6, 2013.
<2> NRC Letter, titled "Susquehanna Steam Electric Station, Units 1 and 2-Request for Additional Information Regarding Request for Changes to Technical Specification Surveillance Requirement 3.65.1.12: (TAC Nos.
MF1955 and MF1956)," dated December 18,2013.
to PLA-7125 Page 2 of8 Response to Request for Additional Information A recent disassembly for inspection of the internal load train provided a visual inspection of parts in one SRV. The disk insert and nozzle seating areas were steam cut and wire drawn. The bonnet adapter internal diameter had some grooves worn into the sleeve. Excessive seat leakage prior to as-found set pressure testing may have contributed to set pressures being outside of acceptance criteria. This conclusion is documented in the Crosby Receipt inspection report for the SRV. With a nameplate set pressure of 1205 psig, subsequent actuations of the SRV were recorded to show the following:
Initial Actuation Second Actuation Third Actuation Fourth Actuation set pressure 1145 psig set pressure 1143 psig set pressure 1136 psig set pressure 1131 psig There have been other LERs for SSES to describe events similar to this most recent OE. These include:
LER 2011-001-00, "Multiple Inoperable Main Steam Safety Relief Valves,"
dated July 1, 2011 LER 2009-001-00, "Multiple Test Failures of Main Steam Safety Relief Valves,"
dated October 12, 2009 LER 2001-005-00, "Multiple Test Failures of Main Steam Safety Relief Valves,"
dated June 11, 2001 LER 2000-007-00, "Multiple Test Failures of Main Steam Safety Relief Valves,"
dated May 15,2000 EICB RAI 2:
Justify the technical analysis as to why the valves appear to operate within their normal design per this statement: "design appears to be adequate and is not considered to be a cause for ADS valve seat leakage as a result of manual operation of the ADS valves," and according to the reference citation 7.3, under the discussion, please explain the apparent contradiction to this statement: "[t]he licensee believes that the failure of the S/RV [safety/relief valve] is related to the manufacturing tolerances of the valve stem and piston assembly and to the lengthy service time without adequate inspection and maintenance." It appears that ADS valves with mechanical issues per design and wear require higher inspection surveillance.
PPL's RESPONSE:
The ADS valves at SSES are Crosby valves. The reference 7.3 is NRC Information Notice (IN) 2003-01, "Failure of a Boiling Water Reactor Target Rock Main Steam Safety/Relief Valve,"
dated January 15, 2003. This reference discusses SRV performance at the Hatch Nuclear Plant and it is not used for technical analysis with respect to the specific valve design for the SRVs at
, SSES. Therefore, the details of the discussion and root cause of valve degradation in the reference are not applicable to the SSES proposal. PPL included this reference to recognize how SRV leakage is an industry issue, and it was not documenting a design deficiency or mechanical issue in SSES ADS valves. Evaluation of OE at SSES by PPL component engineering has to PLA-7125 Page 3 of8 Response to Request for Additional Information concluded that reducing unnecessary cycling of the ADS valves can help to maintain good material conditions of the valve seating areas. Maintaining a good material condition of the valve seating areas improves performance characteristics, reducing seat leakage. Steam cutting and wire drawn surfaces in seating surfaces has been shown at SSES to have contributed to set pressures outside acceptance criteria, and the proposed TS change to reduce unnecessary cycling of these valves will reduce the potential for valve leakage.
EICB RAI3:
The cited material states that the design for a Target Rock valve does degrade and requires periodic inspection, which could mean an increased validation of valve operation is best done with the ADS valve connected to the relief positioner, yet the valves cited in the license amendment request are identified as Crosby valves. Explain the discrepancy.
PPL's RESPONSE:
The reference to IN 2003-01, "Failure of a Boiling Water Reactor Target Rock Main Steam Safety/Relief Valve," dated January 15, 2003, is not a reference for technical analysis with respect to the specific valve design and its application at SSES. The ADS valves at SSES are Crosby valves and not Target Rock. The IN 2003-01 describes experience with how valve actuations at the Hatch Nuclear Plant resulted in eventual misalignments between the main disk and seat. At SSES, disassembly and visual inspection of the internal load train in an SRV experiencing an as-found set pressure outside of acceptance criteria suggests that prior valve actuations have resulted in seat leakage and set pressure drift. Industry OE acknowledges that the number of SRV openings be reduced as much as possible and that unnecessary challenges to the SRV should be avoided.
EICB RAI4:
Provide drawings/sketches/piping and instrument diagrams depicting detailed design of the physical installation of the ADS valve (including information on the actuator such as number and arrangement of solenoids and air system arrangement) the licensee wants to disconnect from the positioner, so the staff can verify the ADS actuator is disconnected from the valve to ensure no damage is done to the valve seat or to the valve internals.
to PLA -7125 Page 4 of8 Response to Request for Additional Information PPL's RESPONSE:
FSAR Figure 5.2-7 shows a simplified schematic. The figure below provides the requested information.
Proposed disconnection point to stroke valves with actuators detached.
VENT TO DRYWELL (CLOSING) 1C601
'-----r---~
1C631
~
1C628
~
ADS VALVES G, J, K, L, M, N LEVER ARM Figure 1: ADS Valve, Actuator and Arrangement of Solenoids and Air System The proposed disconnection point to stroke actuators detached from the valve is shown in the figure above. There is no damage done to the valve seat or to the valve internals by the proposal.
Piping and Instrumentation Diagram (P&ID) M-141, Sheets 1 and 2, Unit 1, Nuclear Boiler, is in. There are six ADS valves in the A, B, C and D main steam lines. These are shown as ADS valves 1F013G, J, K, L, M, and N. A manufacturer's assembly drawing is also provided in Attachment 4.
EICB RAIS:
Provide further discussion on the S/RVs replaced under current practices for a 24 month cycle and how a "main disk exercise test" (referred to on page 3 of 7) performed on all SIR V s at least once every 6 years would ensure the main disks can freely open. This discussion would aid the staff in understanding the operating history of the SIR V s.
to PLA-7125 Page 5 of8 Response to Request for Additional Information PPL's RESPONSE:
The Main Disk Exercise test is performed at Wyle Laboratories during valve testing and overhaul. This test places instrumentation (L VDT or Accelerometers) on the valve disk to monitor travel during bench testing. This test ensures that the disk is achieving proper lift (travel) during bench testing and valve actuation. This test demonstrates proper fit of the disk and disk holder and that there is no binding in the spindle assembly giving assurance that the disk will align properly with the seat.
EICBRAI6:
Provide the cited document in reference 7.2 "INPO [Institute of Nuclear Power Operations]
Event Report, Level3, 11-24, "Maintenance Error results in Uncontrolled Reactor Vessel Depressurization," dated July 26, 2011. The cited material is not available to the NRC in its entirety. Furthermore, the redacted INPO version states the valve failed open. The staff would like to know the relevance to this proposed licensing amendment.
PPL's RESPONSE:
The INPO Event Report in reference 7.2 of the proposal was not used for a technical justification of the proposed change. The reference does not discuss SSES Unit 1 and Unit 2 ADS valve design and operating experience. PPL is not using reference 7.2 in this proposal, and so deletes the citation. Consequently, reference 7.2 has not been provided.
EPNBRAI 1:
Are the actual installed actuators and solenoids shipped and tested with a given ADS valve during off-site bench testing?
PPL's RESPONSE:
Yes. The actuators and solenoid remain attached to the SRVs during shipping. The valves are shipped in specially designed crates to ensure there are no misalignments during shipping.
to PLA-7125 Page 6 of8 Response to Request for Additional Information EPNB RAI2:
Do the set point testing program and the valve control program referred to in Sections 1 and 3 of the referenced letter implement the requirements of American Society of Mechanical Engineers (ASME) operations and maintenance (OM) Code for the testing of the ADS valves? Describe the specific tests performed for these valves to comply with ASME OM Code, Mandatory Appendix I, paragraph 1-3310.
PPL's RESPONSE:
Yes. ADS valve testing is performed in accordance with the test procedure for the Crosby Style 6xRx10 HB-65-BP Safety Relief Valve. Testing performs Solenoid Valve Assembly Seat Leakage Tests, Actuator Leakage Tests, Emergency Operability Tests using each solenoid individually, ADS SRV response time testing, as-found and as-left set pressure testing, seat leakage test, and an air valve leakage test. These periodic tests that are required to be performed for SSES ADS valves comply with ASME OM Code, Mandatory Appendix I, paragraph 1-3310.
EPNBRAI3:
Does the Susquehanna test program for the subject ADS valves fully implement the requirements of ASME OM Code Case OMN-17? In particular, are the valves disassembled and inspected after as-found set-pressure testing?
PPL's RESPONSE:
Yes. All the ADS valves are disassembled and inspected during their 72 month overhaul/certification testing. The SSES test program implements requirements of ASME OM Code Case OMN-17. Disassembly and inspection will verify parts are free from defects resulting from time-related degradation or maintenance induced wear. This maintenance helps to reduce the potential for set point drift, and increases the reliability of these SRV s to perform their design functions.
EPNB RAI4:
Do the tests performed to satisfy TS SR 3.5.1.11 and SR 3.5.1.12 actuates each solenoid independently for a given actuator?
PPL's RESPONSE:
Yes, each solenoid is tested independently. SR 3.5.1.11 is satisfied by two separate tests. This uses the Division 1 and Division 2 ADS Logic System Functional Test procedures. This testing is performed at least every 24 months in connection with the SRs. The SR 3.5.1.12 is satisfied by the ADS Valve Manual Actuation procedure. This testing demonstrates 24 month operability of the six ADS controlled Main Steam Relief Valves (MSRVs) by manually opening each valve/actuator from both Relay Rooms. This test opens each ADS valve/actuator and then tests I
to PLA-7125 Page 7 of8 Response to Request for Additional Information each solenoid independently to ensure the valve would remain open. The proposed change allows for an actuation of the actuator, without a valve stroke.
EPNB RAIS:
Under the proposed new wording of SR 3.5.1.12, is the existing note still necessary that allows for a twelve hour delay in testing?
PPL's RESPONSE:
The existing note in SR 3.5.1.12 allows waiting until12 hours after reactor steam pressure and flow are adequate to perform the ADV valve open test. The note will no longer be necessary when ADV valve opening for this surveillance requirement is replaced with an actuator stroke that does not require reactor steam pressure and flow to perform.
A revised mark-up of the proposed SR 3.5.1.12 without the note is provided in Attachment 2.
A revised portion of the associated TS Bases mark-up is also provided in Attachment 3 for information.
EPNBRAI6:
Does deletion of "on a staggered test basis for each valve solenoid" from the SR 3.5.1.12 frequency requirement mean that each solenoid on each actuator will be individually tested every 24 months?
PPL's RESPONSE:
Yes. Deleting "on a staggered test basis for each valve solenoid" means that all the ADS SRV solenoids will be tested every outage.
STSB RAI 1:
10 CFR 50.36(c)(3), "Surveillance requirements," requires, in part, that SRs be established to ensure that the necessary quality of components is maintained, and that facility operation will be within safety limits.
The proposed SR changes would eliminate the TS requirement to verify that for the ADS valves to open during manual actuation of the ADS circuitry. When performing the testing in-situ as required by the current TSs, the testing verifies that the ADS valve components actuate as designed and discharge lines are not blocked. This test provides assurance that the necessary quality of components is maintained, and that facility operation will be within safety limits.
Please provide a description of the Quality Assurance and Foreign Material Exclusion methods that will be used to provide assurance that the ADS valves that have been bench-tested will actuate as designed and that discharge lines are not blocked once the valves are installed.
to PLA-7125 Page 8 of8 Response to Request for Additional Information PPL's RESPONSE:
Set pressure testing is performed using steam at an offsite test facility as part of certification testing for each of the ADS valves. The proposed change continues to require functional tests, in situ that verify the electrical and pneumatic connections, the actuator and solenoid functions.
Surveillances are still performed to demonstrate the ability of the various logics and controls to actuate the ADS valves up to the point of energizing the solenoids. ADS valves that have been bench-tested will actuate as designed because the proposed change requires the use of overlapping tests that verify the SRVs function properly at operating conditions, and the testing ensures the valves are capable of being opened when installed in the plant. The use of overlapping tests to demonstrate OPERABll.JTY of active components is similar to applications elsewhere in the TS for other systems and components. The proposed change continues to test the active components, and therefore, makes unnecessary the cycling of the ADS valves during startup with reactor steam.
The probability of blocking a discharge line is considered extremely remote. SSES requires the use of good work practices that prevent the introduction of foreign material into a system or component. ADS valve testing, maintep.ance, inspections and preparations for shipment to and from an offsite test facility are performed with requirements subject to Quality Assurance Programs in accordance with 10 CFR 50, Appendix B, and a Foreign Material Exclusion (FME)
Program. These programs and specifications ensure that standards for packaging, shipping, receiving, storage and handling of items for nuclear power plants are properly controlled.
All SRVs, upon receipt and before any further action is taken, are visually inspected. At the offsite test facility, and after completion of testing, the valves are thoroughly cleaned internally and externally to remove all potentially harmful foreign matter. Final cleaning processes are controlled to assure effective cleaning without injuring the surface finishes, material properties or metallurgical structure of the materials. Quality Control inspects the valves prior tore-crating for shipment from the offsite test facility to SSES. After completion of testing, valve assemblies are shipped to the plant without disassembly or alteration of valve components.
SSES performs its receipt inspection in accordance with the requirements of the Quality Assurance Program. Storage requirements in effect at SSES ensure the valves are protected.
Prior to installation the valve will again be inspected for foreign material. Following the initial demonstration during plant startup testing, improper valve functioning or blockage would arise only through assembly errors or the introduction of foreign material into the piping system. The FME program provides the necessary requirements and guidance to prevent and control introduction of foreign materials into structures, systems, and components. These maintenance procedures, FME procedures and practices are sufficient to ensure proper mechanical functioning and unobstructed steam flow capability without periodic actuation testing. The TS Bases for SR 3.5.1.12 also describes that proper operation ofthe valve tailpipes is ensured through the use of FME during maintenance.
to PLA-7125 Technical Specification Markups (Units 1 and 2)
(Revised)
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE SR 3.5.1.9
NOTE--------------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test.
PPL Rev. 4-ECCS - Operating 3.5.1 FREQUENCY Verify, with reactor pressure:::; 165 psig, the HPCI 24 months pump can develop a flow rate ~ 5000 gpm against a system head corresponding to reactor pressure.
NOTE------------------
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signal.
SR 3.5.1.11
NOTE-----------------
Valve actuation may be excluded.
24 months Verify the ADS actuates on an actual or simulated 24 months automatic initiation signal.
SR 3.5.1.12
~JOTE
~Jot required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after.
roaotor steam pressure and flow are adequate to perform tho test.
Verify each ADS valve opens actuator strokes when manually actuated.
24 months e-n-a STAGGERED TEST BASIS for cash val*1e solenoid (continued)
SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE SR 3.5.1.9
NOTE----------------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform the test PPL Rev. 4-ECCS - Operating 3.5.1 FREQUENCY Verify, with reactor pressure :s; 165 psig, the HPCI 24 months pump can develop a flow rate ~ 5000 gpm against a system head corresponding to reactor pressure.
NOTE--------------------
Vessel injection/spray may be excluded.
Verify each ECCS injection/spray subsystem actuates on an actual or simulated automatic initiation signaL SR 3.5.1.11
NOTE------------------
Valve actuation may be excluded.
24 months Verify the ADS actuates on an actual or simulated 24 months SR 3.5.1.12 automatic initiation signal.
NOTE Not required to be performed until12 hours after reactor steam pressure and flow are adequate to perform the test.
Verify each ADS valve opens actuator strokes when manually actuated.
I SUSQUEHANNA-UNIT 2 3.5-6 24 months oo-a STAGGERED TEST BASIS for each valve solenoid (continued)
Amendment ~
to PLA-7125 Technical Specification Bases Markups (Units 1 and 2)
(Revised)
BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.5.1.11 PPL Rev. 2-ECCS-Operating B3.5.1 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to demonstrate that the mechanical portions of the ADS function (i.e.,
solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. SR 3.5.1.12 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform portions of the Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillgmce vvere performed with the reactor at power. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation. This prevents an RPV pressure blowdown.
SR 3.5.1.12 A manual actuation of each ADS valve actuator is performed to verify that the valve and solenoid are functioning properly. This is demonstrated by 00-4 the twe-methods-described below. Proper operation of the valve tailpipes is ensured through the use offoreign material exclusion during maintenance.
One method is by manual actuation of the ADS valve under hot conditions.
Proper functioning of the \\'alve and solenoid is demonstrated by tho response of tho turbine control or bypass valve or by a change in the measmed flow or by any other method suitable to verify steam flow.
Adequate reactor steam dome pressure must be available to perform this test to avoid damaging the val-ve due to seat impact during closure. Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure when the ADS valves divert steam flo'f>' upon opening. Sufficient time is therefore allowed after the required pressure and flovv are achieved to perform this SR. Adequate pressure at which this SR is to be performed is 150 psig. However, tho re*quirements of SR 3.5.1.12 are met by a successful performance at any pressure. Adequate steam flow is represented by at least 1.25 tmbine bypass valves open. Reactor startup is allo¥.'0d prior to performing this SR by this method because 'ralveValve OPERABILITY and the setpoints for (continued)
I SUSQUEHANNA-UNIT 1 TS I B 3.5-16 Revision 4-
BASES PPL Rev. ~
ECC5-0perating B3.5.1 SURVEILLANCE SR 3.5.1.12 (continued)
REQUIREMENTS overpressure protection are verified, per ASME requirements, prior to valve installation. The~efum, this SR is modified 9y a t-lote that states the s~rveillance is not mq~i~ed to 9e peoo~med ~ntil 12 ho~~s afte~ ~eacto~
steam p~ess~~e and flow a~e adeq~ate to peoo~m the test. The 12 holl~s allovved fu~ man~al actblation afte~ the ~eqlli~ed p~ess~~e is ~eached is s~fficient to achieve staele conditions and p~ovides adeqblate time to complete tl=lo S~:~rvoillanco.
Anotl=le~ method is 9y manual Manual actuation of the ADS valve actuator at atmospheric temperature and pressure during cold shutdown is perfoimed.
'Aihon using tl=lis method, p~opor Proper functioning of tho valve actuator and solenoid is demonstrated by visual observation of actuator movement.
Actual disc t~avel is measured d~ring valve rofu~eishment and testing per ASME requirements. Lifting tl=lo valve at atmospl=loric p~ossuro is tho prefe~rod method 9ecause lifting the valves with steam flow increases tl=le likelihood that the valve vtillleak. The ADS actuator will be disconnected from tho valve to ensure no damage is done to the valve seat or to the valve internals. Each valve _shall be bench-tested prior to reinstallation.
The bench-test along With the test on the ADS actuator establishes the OPERABILITY of the valves. The Note that modifies this SR is not noodod
'Athen this method is ~sod 9ocabiSO tho SR is porrormod d~ring cold sh~o~tdown.
SR 3.5.1.11 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function. The Frequency of 24 months on a STAGGERED TEST BASIS ensures that both solenoids for each ADS valve are alternately tested. The Frequency is based on the need to perform the Surveillance under the conditions that apply just prior to or during a startup from a plant outage. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR 3.5.1.13 This SR ensures that the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is less than or equal to the maximum value assumed in the accident analysis. Response Time testing acceptance criteria are included in Reference 13. This SR is modified by a Note that allows the instrumentation portion of the response time to be assumed to be based on historical response time data and therefore, is excluded from the (continued)
I SUSQUEHANNA-UNIT 1 TS/B3.5-17 Revision +
BASES SURVEILLANCE REQUIREMENTS (continued)
ECC~perating 83.5.1 The ADS designated S/RVs are required to actuate automatically upon receipt of specific initiation signals. A system functional test is performed to demonstrate that the mechanical portions of the ADS function O.e.,
solenoids) operate as designed when initiated either by an actual or simulated initiation signal, causing proper actuation of all the required components. SR 3.5.1.12 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function.
The 24 month Frequency is based on the need to perform portions of the Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
This SR is modified by a Note that excludes valve actuation. This prevents an RPV pressure blowdown.
SR 3.5.1.12 A manual actuation of each ADS valve aCtuator is performed to verify that the valve and solenoid are functioning properly. This is demonstrated by ~
the twa-method& described below. Proper operation of the valve tailpipes is ensured through the use of foreign material exclusion during maintenance.
One method is by manual actuation of,A,DS valve under hot conditions.
Proper functioning of the vaiV<l and solenoid is demonstrated by the response of turbine control or bypass valve or by a change in the measured flow or by any other method suitable to verify steam flov'l.
Adequate reactor steam dome pressure must be a"'~ilable to perform this test to avoid damaging the valve duo to seat impact during closure. Also, adequate steam flow must be passing through the main turbine or turbine bypass valves to continue to control reactor pressure 'l'vi'len the ADS valves divert steam flow bipon opening. Sufficient time is therefore allov.red after the required pressure and flow are achieved to perform this SR. Adequate pressure at which this SR is to be performed is 150 psig. Hov,rever, the requirements of SR 3.5.1.12 are met by a successful performance at any pressure. Adequate steam flow is represented by at least 1.25 turbine bypass valves open. Reactor startup is allo\\ved prior to performing this SR by this mothod because valva Valve OPERABILITY and the setpoints for (continued)
SUSQUEHANNA-UNIT 2 TS I B 3.5-15 Revision ~ I
BASES SURVEILLANCE REQUIREMENTS SR 3.5.1.12 (continued)
PPL Rev. ~
ECC~perating 83.5.1 overpressure protection are verified, per ASME requirements, prior to valve installation. Thorof.oro, this SR is modified 9y a ~loto that states tho Surveillance is not roquirod to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure and flow are adequate to perform tho test. Tho 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowed for manual actuation after the roquirod prossuro is roached is sufficient to achiovo stable conditions and provides adeqblato time to comploto tho ablrvoillanco.
Another method is by manual Manual actuation of the ADS valveactuato.r at atmospheric temperature and pressure during cold shutdown is performed.
V\\lhen using this method, properProper functioning of the valve actuator and solenoid is demonstrated by visual observation of actuator movement.
P£tual disc travel is measured during valve refurbishment and testing per
,A.SME requirements. Lifting the valve at atmospheric pressure requires controlling the actuator to sot the valve disc softly on its seat to prevent valve damage. Lifting of tho valves at atmospheric pressure is the preferred method because lifting the valves v.4th steam flow increases the likelihood that the valve 'Nill.leak. Tho ADS actuator will be disconnected from the valve to ensure no damage is done 'to the valve seat or to the valve internals.
Each valve shall be bench-tested prior to re.installation. The bench-test alon*g with the test on the ADS actuator establishes the* OPERABILITY of the*
valves. Tho ~loto that modified this SR is not noo*dod whon this method is blsod bocauso the SR is performed dblring cold shutdown.
SR 3.5.1.11 and the LOGIC SYSTEM FUNCTIONAL TEST performed in LCO 3.3.5.1 overlap this Surveillance to provide complete testing of the assumed safety function. The Frequency of 24 months on a STAGGERED TEST BASIS ensures that both solenoids for each ADS valve are alternately tested. The Frequency is based on the need to perform the Surveillance under the conditions that apply just prior to or during a startup from a plant outage. Operating experience has shown that these components usually pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
SR 3.5.1.13 This SR ensures that the ECCS RESPONSE TIME for each ECCS injection/spray subsystem is less than or equal to the maximum value assumed in the acCident analysis. Response Time testing acceptance criteria are included in Reference 13. This SR is modified by a Note that allows the instrumentation portion of the response time to be assumed to be based on historical response time data and therefore, is excluded from the ECCS RESPONSE TIME testing. This is allowed since the instrumentation (continued)
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