ML18153B400
| ML18153B400 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/10/1993 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18153B401 | List: |
| References | |
| RTR-NUREG-1431 93-768, GL-93-05, GL-93-5, NUDOCS 9312200133 | |
| Download: ML18153B400 (10) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 December 10, 1993 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 and 2 Serial No.
NL&P/ETS Docket Nos.
License Nos.
PROPOSED TECHNICAL SPECIFICATIONS CHANGES AUXILIARY FEEDWATER SYSTEM TESTING 93-768 50-280 50-281 DPR-32 DPR-37 Pursuant to 1 O CFR 50.90, the Virginia Electric and Power Company requests amendments, in the form of changes to the Technical Specifications, to Facility Operating License Nos. DPR-32 and DPR-37 for Surry Power Station Units 1 and 2, respectively. The proposed changes modify the surveillance frequency of the Auxiliary Feedwater System pumps from monthly to quarterly in accordance with the guidance provided in Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation," dated September 27, 1993. Additional changes to the surveillance requirements of valves are proposed to establish a consistent approach for testing of the Auxiliary Feedwater System.
These changes are consistent with NUREG-1431, "Standard Technical Specifications - Westinghouse Plants," dated September, 1992, A discussion of the proposed Technical Specifications changes is provided in.
The proposed Technical Specifications changes are provided in.
It has been determined that the proposed Technical Specifications changes do not involve an unreviewed safety question as defined in 10 CFR 50.59 or a significant hazards consideration as defined in 1 O CFR 50.92. The basis for our determination that these changes do not involve a significant hazards consideration is provided in Attachment 3. The proposed Technical Specifications changes have been reviewed and approved by the Station Nuclear Safety and Operating Committee and the Management Safety Review Committee.
Should you have any questions or require additional information, please contact us.
Very truly yours, qf?~_,_
f~rw. L. Stewart Senior Vice President - Nuclear Attachments
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U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
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The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. P. O'Hanlon, who is Vice President - Nuclear Operations, for W. L. Stewart who is Senior Vice President - Nuclear, of Virginia Electric and Power Company. He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.
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e Discussion of Changes
Discussion of Changes Introduction The NRC has completed a comprehensive examination of surveillance requirements in technical specifications that require testing at power. The evaluation is documented in NUREG-1366, "Improvements to Technical Specification Surveillance Requirements,"
dated December, 1992. The NRC staff found, that while the majority of testing at power is important, safety can be improved, equipment degradation decreased.,. and an..
unnecessary burden on personnel resources eliminated by reducing the amount of testing at power that is required by technical specifications. Based on the results of the evaluations documented in NUREG 1366, the NRC issued Generic Letter 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation," dated September 27, 1993.
The Auxiliary Feedwater System supplies water to the steam generators to remove decay heat from the Reactor Coolant System. To ensure operability of the Auxiliary Feedwater System, the pumps are currently tested on a monthly basis as required by Technical Specifications. Consistent with Generic Letter 93-05, Item 9.1 and NUREG-1366, we are requesting a change to the surveillance testing frequency for the auxiliary feedwater pumps from monthly to quarterly on a staggered test basis. In addition, we are proposing changes to the surveillance requirements for the Auxiliary Feedwater System pumps and valves to provide a consistent testing philosophy. These proposed changes for the pump and valve surveillance requirements are consistent *with NUREG-1431, "Standard Technical Specifications - Westinghouse Plants," dated September, 1992.
Background
The Auxiliary Feedwater System consists of three pumps, two parallel flow paths to the three steam generators and a cross-connect from the opposite _unit supplying the three steam generators. Two of these Auxiliary feedwater pumps are motor driven and power is supplied to each motor by an emergency diesel generator. The third auxiliary feedwater pump is steam driven with the steam supplied by the steam generators through two independent steam supply lines. The normal source of water for the Auxiliary Feedwater System is the Emergency Condensate Storage Tank. The auxiliary feedwater cross connect is designed with redundancy, electrical separation and is Page 1 of 5
capable of supplying water from any of the three pumps in the opposite unit to all three steam generators in the affected unit.
In the past, the NRC has required monthly testing of the pumps to confirm continued operability. However, plant operating and testing experience has indicated that the monthly testing requirement is unnecessary for ensuring the pumps will perform their intended function;* As noted in NUREG-1366, testing the Auxiliary Feedwater System pumps quarterly on a staggered test basis will provide adequate assurance of operability.
The proposed amendment request will require the auxiliary feedwater pumps to be tested quarterly on a staggered test basis. This reduced pump and valve testing frequency should reduce Auxiliary Feedwater System unavailability due to actual testing, as well as failures and equipment degradation during testing. Thus reduced testing results in an improved system reliability. Operability of the auxiliary feedwater pumps will be determined by compliance with ASME Section XI requirements. To provide a consistent approach for surveillance testing of the Auxiliary Feedwater System, surveillance changes are being proposed for the pumps and valves.
Specific Changes The definition of "staggered test basis" is included in Section 1.0, Definitions, to accommodate testing the Auxiliary Feedwater System pumps quarterly on a staggered test basis.
The test frequency noted in Technical Specification Table 4.1-2A, Item 20, Containment Hydrogen Analyzers is changed from "staggered basis" to "STAGGERED TEST BASIS" for consistent terminology.
The Surveillance Requirements for the Auxiliary Feedwater System in Specification 4.8 are modified as follows:
A new requirement is being added to verify that manual, power operated and automatic valves in each flow path are in the correct position at least once per 31 days. This verification includes valves that are not locked, sealed, or otherwise secured in position, valves in the the cross-connect from the opposite unit and Page 2 of 5
valves in the steam supply paths to the turbine driven auxiliary feedwater pump.
(new Specification 4.8.A.1.a)
The requirement for monthly exercising of the pump discharge valves is deleted.
In its place, a new requirement is being added to verify quarterly that each motor-operated valve in the auxiliary feedwater flow paths, including the cross-connect from the opposite unit, performs -satisfactorily when tested in accordance with Specifications 4.0.5. Specification 4.0.5 invokes the testing and acceptance criteria of ASME Section XI. (new Specification 4.8.A.2.a)
The requirement to perform pump operability testing monthly is changed to quarterly on a staggered test basis. (new Specification 4.8.A.3.a)
The acceptance criterion in Technical Specification 4.8.A is changed from "flow test for 15 minutes to determine operability" to "performs satisfactorily when tested in accordance with Specification 4.0.5." Specification 4.0.5 invokes the testing and acceptance criteria of ASME Section XI.
(new Specification 4.8.A.3.a)
The requirements to test the motor driven auxiliary feedwater pumps during periods of extended shutdown are modified to be consistent with the proposed quarterly testing during plant operations. Specifically, the testing requirement for motor driven pumps during shutdown is changed from monthly to quarterly on a staggered test basis and will require the pumps to satisfy the acceptance criteria of Specification 4.0.5. Therefore, the motor driven pumps are tested quarterly on a staggered test basis with the unit operating or shutdown. (new Specification 4.8.A.5.a & 5.b)
The Basis of Specification 4.8 is changed as follows:
To identify Specification 4.0.5 which invokes ASME Section XI as the acceptance criteria for the operability testing of the pumps.
To discuss the basis for.the periodic verification of valve positions in the water and steam flow paths for the Auxiliary Feedwater System.
Page 3 of 5
To provide clarification of the opposite unit's Auxiliary Feedwater operability and testing requirements. The motor driven auxiliary feedwater pumps will continue to be tested quarterly on the same staggered test basis when the unit is shutdown in order to support the opposite unit. The turbine driven pump is not required to be operable when the unit is shutdown. Therefore, the turbine driven pump is not tested during periods of shutdown.
Various administrative changes are being completed to provide consistency throughout the Technical Specifications.
The following type of changes are included: 1) punctuation and grammar, 2) correction of system or component names, and, 3) capitalization of defined words.
Safety Significance The proposed changes to the surveillance requirements for the Auxiliary Feedwater System are consistent with the intent of Generic Letter 93-05, "Line-Item Technical Specifications Improvement to Reduce Surveillance Requirements for Testing During Power Operation," dated September 27, 1993 and NUREG 1431, "Standard Technical Specifications - Westinghouse Plants," dated September, 1992. The proposed changes will modify the surveillance frequency and acceptance criteria for the Auxiliary Feedwater System pumps and valves. The Auxiliary Feedwater System valves will be tested quarterly and the pumps will be tested quarterly on a staggered test basis.
Changing the test frequency and acceptance criteria of the Auxiliary Feedwater System pumps and valves does not affect the probability of occurrence or the consequences of the accidents identified in the UFSAR. The probability of an accident occurrence is not increased by the proposed changes in testing of the Auxiliary Feedwater System components.
No new accident precursors are being generated by the proposed surveillance requirements. Further, quarterly testing and ASME Section XI acceptance criteria for the Auxiliary Feedwater System pumps and valves provides assurance that the system is capable of performing its intended safety function for either unit.
Therefore, the consequences of a postulated accident are not increased by this change in surveillance requirements for the Auxiliary Feedwater System pumps and valves.
The reduced testing frequency of the Auxiliary Feedwater System pumps and valves may insignificantly increase the probability of: 1) a malfunction of a pump, 2) a valve to Page 4 of 5
operate and, 3) blockage of a flow path, when required to perform its intended safety function. However, the overall system unavailability caused by reduced testing is decreased. The failure of a pump or valve to operate or blockage of flow to one steam generator is within the design basis, and an active single failure will not increase the consequences of any malfunctions identified above.
-Testing of the Auxiliary Feedwater System pumps will continue to be performed through the full-flow test lines. The pumps will be tested quarterly on a staggered test basis instead of monthly. The pump discharge valves will no longer be exercised every month. However, the valves in the Auxiliary Feedwater flow paths will be verified to be in the correct position at least monthly (31 days) and stroked quarterly in accordance with the lnservice Testing Program. These changes in the surveillance requirements do not affect plant or Auxiliary Feedwater System operations. Therefore, no new accident precursors are being generated by the proposed surveillance changes for the Auxiliary Feedwater System.
The Technical Specifications operability requirements for the Auxiliary Feedwater System are not being changed. The quarterly testing of the pumps and valves is adequate to ensure the Auxiliary Feedwater System will be capable of performing its intended function for either unit. Therefore, the change in test frequency for the Auxiliary Feedwater System components does not reduce the margin of safety as described in the Technical Specifications.
Therefore, an unreviewed safety question is not generated by this change in test frequency for the Auxiliary Feedwater System pumps and valves. This reduction in test frequency of the auxiliary feedwater pumps at power has been examined and accepted by the NRC staff in Generic Letter 93-05, Item 9.1. The staff found that while the majority of the testing at power is important, safety can be improved, equipment degradation decreased, and an unnecessary burden on personnel resources eliminated by reducing the amount of testing at power that is required by technical specifications.
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,' t Technical Specifications Changes