ML17250B052
| ML17250B052 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/07/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17250B051 | List: |
| References | |
| NUDOCS 8911140181 | |
| Download: ML17250B052 (15) | |
Text
+ ~
O~
Cy \\
C1
++*++
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 Enclosure e I SAFETY EVALUATION BY.THE
~ OFFICE-OF NUCLEAR REACTOR REGULATION TECHN UMPS 0
C N
1.0 INTRODUCTION
A.
Purpose The licensee for the R.
E. Ginna Nuclear Power Plant, the Rochester Gas and Electric Corporation (RGE), in a submittal dated May 9, 1989 proposed to change the Turbine Cycle Technical Specifications.
The licensee's intention was to modify "...for clarity, and to incorporate changes to the Action Statements for the motor driven and turbine driven auxiliary feedwater pumps and associated flow paths, as well as a change to the testing requirements for the turbine driven auxiliary feedwater pump."
Based on its review of the proposed
- changes, the staff concludes that the licensee did not attain the goal of clarity.
- Further, the staff finds that the proposed TS changes do not provide sufficient assurance of required AFW system operability.
Therefore, the staff is providing in the accompanying evaluations below "model" technical specifications for the Ginna AFW system using the Standard Technical Specifications for Westinghouse Pressurized Water Reactors (NUREG-0452) as the basis, with some modifications made to account for differences between the Ginna AFW systems and more typical plant designs.
The staff is also providing a critique of those Technical Specification changes proposed by the Ginna licensee, and suggests changes so as to bring them into conformance more closely with the STS.
In addition, the staff is providing an evaluation of the changes proposed by the licensee to the Technical Specifications for the main steam safety valves (MSSVs).
The staff finds the proposed MSSV Technical Specification changes to be acceptable.
B.
Description of the Ginna AFW System The Ginna Nuclear Plant has an AFW system with two subsystems, the main auxiliary feedwater (MAFW) system and the standby AFW system.
The MAFW system consists of three
- pumps, two of which are motor driven while the third is driven by a steam turbine.
The primary water supply for the three AFW pumps comes from the condensate storage tanks (CSTs) by gravity feed.
These tanks are required by Technical Specifications to maintain a minimum water supply of 22,500 gallons for the MAFW pumps.
A backup supply of water is provided by the service water system which takes water from Lake Ontario in the event that the CST supply is not available.
f
S91 1140181 891107 PDR
- DOCK 05000244 P
PNU
The HAFW system is normally separated into three trains, one for each motor driven pump, and one for the turbine driven pump.
The motor driven pumps normally feed separate steam generators (A or B), but can be aligned to permit feeding either steam generator.
The turbine driven AFM pump train normally feeds both steam generators.
The motor driven pumps in the MAFM system start automatically if the level in one SG decreases to a low-low level of 17%.
The steam turbine driven pump starts if the level in both SGs decreases to that level.
The standby AFM fSAFM) system is intended for use in the event a main steamline break outside containment causes the HAFM system to fail because
<t is,not qualified to operate in the potentially harsh steam environment which can result from the steamline break.
The SAFW system is a two-pump, two-train system which is separated from the MAFM system, and is started manually.
The water supply for the SAFW system is provided by the service water system.
The SAFM system also contains a condensate supply tank with a capacity of 10,000 gallons which is normally used for testing the SAFW system pumps.
II.
Model Technical Specifications for AFM Systems A.
Hain Auxiliary Feedwater System l.
Ob.jective The fol'owina model Technical Specification is provided in order to define the operability requirements o
the Ginna AFM system and the actions to he taken in order to maintain that operability, and thereby ensure the capability to remove decay heat from the core when required.
2.
Limiting Condition for Operation When the RCS temperature is at or above 350'F, the following conditions shall he met:
At least three independent main auxiliary feedwater pumps and associated flow paths shall he OPFRABLE with:
a.
Two RAFM pumps, each capable of being powered from separate OPERABLF.
emergency
- busses, and b.
One NFM pump capable of being powered from an OPERABLE steam supply system.
The associated flow path includes the path of water from the condensate storage
~anks to the steam generator.
For the turbine driven pump only, an associated flow path includes the flow path of steam from the steam generator to the pump turbine.
3.
'a ~
Action Statement With one motor driven main auxliary feedwater pump inoperable, restore the required auxiliary feedwater pumns to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the Reactor Coolant System (RCS) below 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
b.
With the turbine driven main auxiliary <eedwater pump inoperable, restore the oump to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS below 350'F within the <ollowing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
c.
With two or more main auxiliary feedwater pumps inoperable be in at least HOT SHUTOOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS below 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
4.
Surveillance Requirements Each auxiliary feedwater pump shall be demonstrated OPERABLE:
a.
At least once per 31 days on a staggered basis by:
(1)
Veri<ying that each motor driven pump develops a discharge pressure of greater than or equal to psio at a flow of greater than or equal to 200 cpm.
(2)
Verifying that the turbine driven pump develops a discharge pressure of greater than or equal to psig at a flow of greater than or equal to 400 gpm when the secondarv steam supply pressure is greater than psig.
pon enterinq the operatinq mode the oDerability of the turbine riven pump must be veritied be~ore ex':ceding a power level of 5g.
(3)
Verifying that each non-automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct positions b.
The main AFW system shall be demonstrated operable at least once per 18 months during shutdown by:
(1}
Verifying that each automatic valve in the main AFW flow oath actuates to its correct position upon receipt of an auxiliary feedwater actuation test signal.
(2)
Verifying that each pump starts automatically upon receipt of an auxiliary feedwater actuation test signal.,
B.
Standby Auxiliary Feedwater (SAFW) System l.
Ob;;ective The fo~ lowing model Technical Specification is provided in order to define the operability requirements of the SAFW system and the actions to be taken in order to maintain that operability, and thereby ensure the capability to remove decay heat from the core for those events required.
2.
Limiting Condition for Operation When the RCS temperature is at or above 350'F, the following conditions shall be met.
At least two independent steam generator standby auxiliary feedwater pumps and associated flow paths shall be operable with two SAFW pumps, each capable of being powered from a separate operable emergency buss.
The associated flow path includes the path of water from the service water system to the steam generator.
3.
Action Statement a.
With one standby auxiliary feedwater Dump inoperable and at least two main auxiliary feedwater pumps operable, restore the required standby auxiliary feedwater pumps to OPERABLE status within 14 days or be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS below 350'F within the <ollowing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
b.
With both standby auxiliary +eedwater pumps inoperable and at least two main auxiliary feedwater pumps operable, restore at least one standby auxiliary feedwater pump to operable status within 7 days or be in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS below 350'F within the following 6 hnurs.
If only one AFW pump is operable, be in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS below 350'F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
If no AFM pump is operable, immediately initiate corrective action to restore at least one main auxiliary feedwater or standby auxiliary feedwater pump to OPERABLE status as soon as possible.
4.
Surveillance Requirements Each standby auxiliary feedwater pump shall he demonstrated OPERABLE:
a.
At least once per 31 days by:
(1)
Verifying that each pump develops a discharge pressure o~ greater than or equal to psia at a flow of greater than or equal to 200 gpm.
(2)
Verifying that each valve not operable from the control room in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.
b.
At least once per 18 months during shutdown by:
Verifying that the SAFWS pumps can be initiated from the control room.
C.
Mater Supoly for Hain Auxiliary Feedwater and Standby Auxiliary Feedwater Systems 1.
Obiective The following model Technica>
Specification is provided in order to ensure availability of an adenuate source of water for the MAFW and SAFW systems.
2.
Limiting Condition for Operation a.
The condensate storage tanks (CST) shall be operable with a contained volume of at least 22,500 gallons whenever the RCS temperature is above 350'F.
b.
The service water system as the main supply to the SAFW pumos and as a backup supply for the MAFW pumps shall be operable whenever the RCS temperature is above 350'F.
3.
Action Statement a.
With the condensate storaae tank inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:
(I)
Restore the CST to OPERABLE status or be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS temperature below 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or (2)
Demonstrate the OPERABILITY of the service water system as a backup supplv to the main auxiliary feedwater pumps and restore the condensate storage tank to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS temperature below 350 F within the followina 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
b.
Witb the service wa.er system to a SAFW pump inoperable, declare the SAFW pump inoperable.
Restore the service water supply to ope~able status within 14 days or be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS temnerature below 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Survei liance Requirements a.
The condensate storage tank shal>
be demonstrated OPERARLF. at >east once Der 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying the contained water volume is within its limits when the tank is the supply source
<or the main auxiliary feedwater pumps.
b.
The service water supply tr the standby auxiliary feedwater and main auxiliary
<eedwater pumps shall be demonstrated operable at least once every 31 days."
III. Critique of Ginna Proposed Technical Specifications The proposed Technical Speci<ication for the Ginna auxiliary feedwater systems were reviewed and compared with the model Technical Specifications proposed by the staff, below.
The Technical Specification numbers used here are the same as thnse in the licensee's listing and are utilized for ease of comparison.
Changes are suggested so as to have the Teel nical Specifications here conform more closely with those in the STS.
Note that the licensee has proposed to revise the Technical Specifications for the Ginna AFW svs~em almost completely with the exception of Action Specification 3.4.3.a.
We have inserted the word "main" in the 1'.censee's specifications to dif+erentiate between the total (AFW) system and its two subsvstems in order to avoid confusion.
3.4.2 Main Auxi1iary Feedwater 3.4.2.1 Main Motor driven Auxiliary Feedwater Supply With the RCS temperature at or above 350'F, both main motor driven auxiliary feedwater oumps must be operable, each with an operable discharge flow path to its resoective steam generator.
Action a ~
With one motor driven main auxiliary feedwater pump or discharge flow path inoperable, satisfy the requirements of 3.4.2.2.c.
If the pump or flow path is not operable within 7 davs, submit a Special Report within an additional 30 days in accordance with Specification 6.9.2 outlining the cause of inoperability and plans
<or restoring the pump or flow path to operable status.
b.
With both motor driven main auxiliary ~eedwater pumps or discharge flow paths inooerabie, restore a
nump and flow path to one steam qenerator to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in hot shutdown within the next 6
hours and at an RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The staff considers the "Specification" portion unacceptable because it concerns itself only with an AFW motor driven pump and its discharqe path.
The word "discharge" should be deleted thereby assuring an operable pump with a complete flow path, including the suction line.
This change should also be made appropriately, in Action Statements 3.4.2.1 a and b.
The first part of Action Statement "a" requires that the operator satisfv the requirements of Action Statement 3.4.2.2.c with one motor driven PFW pump or discharqe path inoperable.
Action Statement 3.4.2.2.c reouires that the turbine driven pump together 'with its discharge path to and steam admission path from the steam generator fed by the inoperable motor driven pump be
- operable, allowing 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
+or anv inoperability therein to be corrected before proceeding to hot shutdown.
The acceptability of this statement is discussed in detail under Section 3.4.2.2.c, in sequence below.
The second portion of Action 3.4.2.l.a is not. satisfactory.
It permits a
motor driven pump to be inoperable for a period as long as 37 days until the Commission is advised of the ~icensee's plans.
This outage period continues while the NRC staff examines those plans for restoration of pump operability, and is extended while a response is prepared by the staff.
This outage continues while the licensee perfects the olans and, finally, only ceases once the plans are put into action and the necessary corrections or modifications are made.
Thus, the outage could continue for an extended period of time at d, as guided by the specification, has no limitation.
Furthermore, by requirina staff approval of any proposed plan for corrective action, the Commission is in the position of being responsible, at ~east partly, for the length of outage time during which the plant is operating with a degraded AFW svstem.
For these
- reasons, Action Statement 3.4.2.1.a is unacceptable.
The statement should be modified hy deleting everything beyond "7 days" and adding the following-
"be in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F within the <ollowing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."
Action Statement 3.4.2. l.b is unsatisfactory as is because, in contrast to the STS, it permits the two motor driven pumps to be inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before initiating shutdown.
The licensee should adopt the STS position by requiriqg that shvtdqwn be initiatgd upon inoperabilitv of two AFW pumps.
This may be aone by deleting the words restore a
pump...within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or..."
3.4.2.2 MAIN TURBINE DRIVEN AUXILIARY FEEPl!ATER SUPPLY Specification With the RCS temperature at or above 350'F the turbine driven auxiliary feedwater pump, both steam admission and both discharge flow paths must be operable.
The steam turbine driven auxiliary feedwater pump must be shown to be operable prior to exceeding 5X powe~.
Action a.
l'ith one steam admission flow path or pump discharae flow oath inoperable, restore to operab1e status within 7 days or submit a Special Report in accordance with Speci~ication 6.9.2 outlinina the cause for inoperability and pla'ns
<or restoring to operable status.
b.
With the turbine driven auxiliary feedwater pumo or both discharoe
~low paths or both steam admission flow paths inoperable, restore the inoperable pump and a discharge flow path and a steam supply associated with the same steam aenerator to operah1e status within 7 days or be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
c.
With one main motor driven auxiliary ~eedwater pump or discharge flow path inoperable, the turbine driven auxiliary feedwater pump, the steam admission flow path from, and discharge flow path to, the steam generator that is alianed w'th the inoperable motor driven pump shall he ooerable, or restore the turbine driven pump or flow path(s) associated with that steam generator to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an PCS temperature less than 350"F in the followinq 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
In the specification section of 3.4.2.2, the entire flow path of water including the suction supply ~rom the CSTS to the pump should be included in the overall path by changing the words "..both steam admission and both discharge flow paths..." to "both steam admission paths and both flow paths..."
Similar changes should be made, as appropriate, in action statements 3.4.2.2 a, b and c.
Action statement "a" should be modif'ed by de1eting everythina following "within 7 days" and replacing it by adding "...or be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS at a
temperature less thar
?50'F in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."
The reasonina for this change is the same as that given for action statement 3.4.2.I.a, above.
Action Statemient.
"b" should be revised to substitute an allowable repair time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in lieu o+
7 days consistent with the Standard Technica1 Specifications.
~
~
4
/
Action statement "c" should be deleted because it is confusing and unnecessary once the licensee corrects the technical specifications to conform with present standards as recommended in this discussion.
3.4.2.3 STANDBY AUXILIARY FEEDMATER SUPPLY S ecification With the RCS temperature at or above 350'F, both standby auxiliary feedwater pumps and their associated discharge flow paths, including cross-connects, shall be operable.
Action With one standby auxiliary feedwater pump or its discharge or crosstie f'low path inoperable, restore the pump and flow path(s) to operable status within 7 days or be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Here, again, the specification section should include the entire flow path (including suction side of the pumps).
The inoperability time specified in the Action Statement should be extended to 14 days for one pump provided that at least two t~iAFW pumps are operable.
This extension is allowable because the SAFW system is a backup to the MAFW system, and is required only in the event of a steam break outside containment which causes damage to all the nonenvironmentally qualified AFW pump trains.
Under all other accidents and transients
- events, the HAFW system is the primary source of delivery o< water to the steam generators
<or decay heat removal.
The operability of the crosstie for the SAFW system need not be included in the Technical Specifications since it is not depended upon or mitigation of transients or accidents.
The above action statement should be identified as action statement "a".
The following should be added as action statement "h".
b.
With both standby auxiliary feedwater pumps inoperable and at least two main auxiliary feedwater pumps operable, restore at least one pump to operable status within 7 days or be in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS below 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
If only one MAFW pump is operable, be in at least HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and have the RCS below 350'F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
If no AFW pump is operable, immediately initiate corrective action to restore at. least one auxiliary feedwater or standby auxi~iary feedwater pump to OPFRABLE status as soon as nossible."
3.4.3 SOURCES OF AUXILIARY FEEDWATER S ecification With the RCS temperature at or above 350'F, the following sources of auxiliary feedwater shall be operable:
a.
The condensate storage tanks with a minimum of 22,500 gallons of water and flow oaths to the motor driven and turbine driven main auxiliary feedwater
- pumps, and
)
b.
Service water supply to the motor driven main and standby auxiliary feedwater pumps; and c.
Service water supp>y to the turbine driver auxiliary feedwater pump if one motor driven main auxiliary feedwater pump or discharge flow path is inoperable.
Action a.
With the required 22,500 gallons o< water unavailable in the condensate storage tanks, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either
- 1) restore the required amount of water, or
- 2) demonstrate the operability of the service water system as a backup water supply,to the main auxiliary feedwater svstem and restore the required amount of water in the condensate storage tanks within 7 days, or 3) be in hot shutdown within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
b.
With the service water system or service water flow path to any motor driven main or standby auxi>iary <eedwater pump inoperable, declare the affected pump inoperable.
c.
With the service water flow path to the turbine driven auxiliary feedwater pump inoperable, when one motor driven main auxiliary feedwater pump or discharge flow path is inoperable, declare the turbine driven pump inoperable.
The specification section of 3.4.3 should be modified by changing "b"
to include the service water (SW) supply as the secondary (backup) water supply for the hAFW pumps and as the primary supply for the SAFW pumps.
Specification "c" should be deleted since there need be no qualification as to when the SW supply should be available to the turbi ne driven AFW pump; it should be available at all times the CST supply is not available.
This is also true for the motor driven MAFW pumps.
Action Statement "b". should be changed to the followinq:
With the service water supolv to any standby auxiliarv ~eedwater pump inoperable, declare the pump inoperable and restore the service water supply to operable status within 14 days or be in hot shutdown within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> thereafter and at an RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
v
~ 'V.
Testing of AFW Pumps The Technical Specifications proposed by the licensee
<or testing of the AFW pumps are contained in l)irma Specification 4.8.
Mote that the licensee proposes to change only the latter portion of Specification 4.8.2 to allow for testing of the turbine driven pump in the event one flow path is inoperable by establishment o< a lower flow rate throuoh that path.
4e8 AUXILIARY FEEDWATER SYSTEMS
~A>> i Applies to periodic testing requirements of the turbine driven and motor driven auxiliary feedwater pumos and of the standby auxiliary feedwater pumps.
~ob 'ective To verify the operability of the auxiliary feedwater system and the standby auxiliary fcedwater system and their ability to respond properly when required.
S ecification 4.8.2 Except during cold or re~ueling shutdowns each motor driven
'uxiliarv feedwater pump unless it is declared inoperable without testing will be started at intervals not to exceed one month and a
~lowrate of 200 gpm established.
Except during cold or refuelino shutdowns the steam turbine driven auxiliary feedwater pumo unless it is declared inoperable without testing will be started at intervals not to exceed one month and a
~lowrate of 400 gpm established.
If one discharge flow is inoperable in accordance with Specification 3.4.2.2.a, a flow o< 200 gpm must be establishede 4.8.3 Except during cold or refueling shutdowns the auxiliary feedwater pumps suction discharge and crossover motor operated valves shall be exercised at intervals not to exceed one month.
4.8.4 4.8e5 Except during cold or refueling shutdowns each standby auxiliary feedwater pump unless it is declared inoperable without testing, will be started at intervals not to exceed one month and a flowrate of 200 gpm established.
Except during cold or re~ueling shutdowns, the suction, discharge, and cross-over motor operated va>ves for the standby auxiliary feedwater pumps shall be exercised at intervals not to exceed one month.
4.8.6 These tests shall be considered satisfactory if control board indication and subseouent visual observation of the equipment demonstrate that all components have operated properly.
These tests shall he performed prior to exceeding 5X power during a
startup i< the time since the 1as? test exceeds one month.
4.8.7 At least once per 18 months, control nf the standby auxiliary feed system pumps and valves from the control room will be demonstrated.
4.8.8 At least once per 18 months during shutdown:
a.
Verify that each automatic valve in the flow oath for each auxiliary feedwater pump actuates to its correct position upon receipt of each auxiliary <eedwater actuation test signal.
b.
Verify that each auxiliary feedwater pump starts as designed automatically upon receipt o~ each auxiliary feedwater actuation test signa1.
4.8.9 Each instrument channel shall be demonstrated OPERABLE by the performance o~ the CHANNFL CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.1-1.
4.8.10 The
RESPONSE
TIME of each pump and valve required
+or the operation of each "train" of auxiliary feedwater shall be demonstrated to be within the limit of 10 minutes at least once per 18 months.
The wording in the second sentence of the licensees proposed change to Specification 4.8.2 should be changed to read "If one discharge flow path is inoperable, a <low of 200 gpm must be established."
An additional line should be added, as follows:
"Once the inoperable discharge flow path is returned to operab1e
- status, a flow of 400 gpm must be established within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter."
In so doing, the question of action to be taken is left, properly, within that portion of the overall specification where such statements
- belong, and the pump.is tested at full flow once the system is able to accommodate it.
A note should also be added to specification 4.8 to indicate that pumps should be tested on a staggered basis in conformance with the Stardard Technical Specification.
V.
MAIN STEAM SAFETY VALVES 3.4.1 Main Steam Safety Valves Specification Except during testing of the main steam safety valves, with the RCS temperature at or above 350'F, a minimum turbine cycle code approved steam relieving capability of eight {8) main steam safety valves shall be available.
Action With one or more main steam code safety valves inoperable, restore the inoperable valve(s) to operable status within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and at an RCS temperature less than 350'F within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
The licensee made no technical chanqes in this specification except to rearrange it so as to separate it from those for the AFW system.
We find this acceotable because it is only an administrative change to a previously aporoved Technical Specification.
VI.
CONCLUSIONS The staff has provided model Technical Specifications for the Ginna AFW system using the STS as a guide as modified to account for the plant-specific differences over the "standard" plant AFW system.
The staf< has also reviewed the Technical Specifications proposed hy the licensee and identified changes to them to bring them more closely in compliance with the current Standard Technical Specifications.
These changes account for the fact that Ginna has two additional AFW pumps, those in the standby AFW system, specifically designed to provide feed-water to the steam generators in the event a steam line break outside of containment renders the "normal" AFW svstem inoperable because it is not environmentally qualified.
Specific summary comme ts on the licensees proposed Technical Specifications are:
( I)
In the narrative (Bases),
the licensee dwells upon the use of'he AFW turbine driven pumo in mitigation of a Station Blackout (SB01 Event.
It should be noted that SBO is a separate consideration.
The AFM system Technical Soecifications are intended to ensure operability of the system for all design basis accidents and transients and should conform to the recommendations of Item II.E.l.1 of NUREG-0737, "Clarification of TMI Action Plan Requirements."
These guidelines do not include SBO.
The licensee should modify the AFW system Technical Specification bases as appropriate when proper Technical Specifications are proposed.
(2)
The licensee's Technical Speci
'.cations contain Action Statements for an inoperable motor driven AFW pump and for one inoperable turbine driven flow path, to allow the pump or path to be inoperable for a period in excess of 5 weeks (37 days) without any limitation thereafter, except to say:
"If the pump or flow path is not operable within 7 days, submit a Special Report within an additional 30 days in accordance with Specification 6.9.2 outlining the cause of inoperability and plans for restoring ihe pump or flow path to operable status."
(For the turbine driven pump, the 30 days was omitted, apparently by accident since the previous specification included the 30 day limitation for all 3
AFW pumpsl.
The staff finds this to be unsatisfactory as indicated above.
Based on the above, the staff concludes that the licensees proposed AFW system Technical Specifications are unacceptable for ensurinq adequate system operability.
The long outage times proposed bv the licensee for some AFM components are inaporopriate, considering the importance of the safety function performed by the AFW system in removing decay heat during transients and accidents.
The licensee should, therefore, propose revised AFM system Technical Specifications consistent with the model Technical Specifications and comments which have been provided.
The staff also concludes that the proposed main steam sa ety valve Technical Specification change is only administrative in nature and is acceptable.
Principal Contributor:
Norm Wagner Dated:
November 7, 1989
I J'k e
~
~
4
Dr.. Robert C. Mecredy cc w/enclosure:
Harry H. Voigt, Esouire
- Le8oeuf, Lamb, Leiby and MacRae 1333 New Hampshire
- Avenue, N.W.
Suite 1100 Vashington, O.C.
20036 Resident 1nspector R.E.
Ginna Plant U.S.
Nuclear Regulatory Commission 1503 Lake Road
- Ontario, New York 14519 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Ms.
Donna Ross Division nf Policy Analysis Im. Planninq New York State Energy Office Agency Building
?
Empire State Plaza
- Albany, New York 12223 Mr. Bruce A. Snow, Superintendent Nuclear, Droduction Rochester Gas Im Electric Corporation 89 East Avenue Rochester, New York 14649-0001 Charlie Donaldson, Esq.
Assistant Attorney General New vork Department of Law 120 Broadway New York, New york 10271