ML20005E487

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Proposed Tech Specs Deleting Requirement for Monthly Testing of Auxiliary Feedwater Pumps While Retaining Quarterly Tests & Monthly Valve Lineup Check
ML20005E487
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 12/28/1989
From:
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20005E486 List:
References
NUDOCS 9001050323
Download: ML20005E487 (20)
v • d • e


Text

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Attachment 1 .

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Proposed Technical- Specification. Chances North Anna Power Station Units 1 and 2 .

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l Virginia Electric and Power Company l:'

I 9001050323 891228 PDR- ADOCK 05000338 PNV

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PLANT SYSTEMS AUXILIARY FFEDWATER SYSTEM LIMITING CONDITION FOR OPERATION 3.7.1.2 At least three independent steam generator auxillary feedwater pumps and associated flow paths shall be OPERABLE with:

a. Two motor driven auxiliary feedwater pumps, each capable of being powered from separate emergency busses, and
b. One steam turbine driven auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABILITY: MODES 1,2 and 3. l ACTION-

a. With one auxiliary feedwater pump inoperable, restore the required auxiliary feedwater pumps to an 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 following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, j l

L b. With two auxiliary feedwater pumps inoperable be in at least HOT STANDBY within 6 ,

hours and 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 />.  !

c. With three auxiliary feedwater pumps inoperable, immediately initiate corrective action to restore at least one auxiliary feedwater pump to OPERABLE status as soon as possible.

SURVEILLANCE REOUIREMENTS 4.7.1.2 Each steam generator auxiliary feedwater subsystem shall be demonstrated OPERABLE by:

a. Testing the auxiliary feedwater pumps pursuant to Specification 4.0.5. The provisions of Specification 4.0.4 are not applicable to steam driven pump testing, l

NORTH ANNA - UNIT 1 3/4 7-5

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4 PLANT SYSTEMS

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- SURVEILLANCE REQUIREMENTS (Continued)

b. At least once per 31 days verifying that each valve'(manual, power operated' or l .

automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is In its correct position.

c. At least once per 18 months during shutdown: l.
1. Verifying that each automatic valve in the flow path actuates to its correct position on an auxiliary feedwater actuation test signal.
2. Verifying that each auxiliary feedwater pump starts automatically upon receipt of an auxiliary feedwater actuation test signal.
d. The auxiliary feedwater system shall be demonstrated OPERABLE prior to entry into l MODE 3 following each COLD SHUTDOWN by performing a flow test to verify the normal flow path from the emergency condensate storage tank through each auxiliary feedwater pump to its associated steam generator.

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NORTH ANNA - UNIT 1 3/4 7-6 l

1 L PLANT SYSTEMS

' AUXILIARYFEEDWATERSYSTEM UMITING CONDITION FOR OPERATION 3.7.1.2 At least three independent steam generator auxillary feedwater pumps and associated flow paths shall be OPERABLE with:

a. Two motor driven auxiliary feedwater pumps, each capable of being powered from separate emergency busses, and
b. One steam turbine driven auxiliary feedwater pump capable of being powered from an OPERABLE steam supply system.

APPLICABILITY: MODES 1,2 and 3.

ACTION:

a. With one auxiliary feedwater pump inoperable, restore the required auxiliary feedwater pumps to an 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 following 6 -hours.
b. With two auxiliary feedwater pumps inoperable be in at least HOT STANDBY within_6 hours and 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 />,
c. With three auxiliary feedwater pumps inoperable, immediately initiate corrective acilon to restore at least one auxiliary feedwater pump to OPERABLE status as soon as possible.

SURVEILLANCE REQUIREMENTS .

4.7.1.2 Each steam generator auxiliary feedwater subsystem shall be demonstrated OPERABLE by:

a. Testing the auxiliary feedwat9r pumps pursuant to Specification 4.0.5. The provisions of Specification 4.0.4 are not applicable to steam driven pump testing.

NORTH ANNA - UNIT 2 3/4 7-5

1 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) l

b. At least once per 31 days-verifying that each valve (manual, power operated _or l '

automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

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' c. At least once per 18 months during shutdown:

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1. Verifying that each automatic valve in the flow path actuates to its correct position on an auxiliary feedwater actuation test signal, .t
2. Verifying that each auxiliary feedwater- pump starts automatically upon receipt of an auxiliary feedwater actuation test signal.
d. The auxiliary feedwater system shall be demonstrated OPERABLE prior to entry into l MODE 3 following each COLD SHUTDOWN by performing a flow test to verify the normal flow path from the emergency condensate storage tank through each auxiliary feedwater pump to its associated steam generator.

NORTH ANNA - UNIT 2 3/4 76

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The following pages contain the MERITS TS version of the proposed change and marked-up pages of the current specification to illustrate the change.'The enclosed MERITS TS pages are identical to those submitted in our October 16, 1989 letter (Serial No. 89 725) transmitting the North Anna MERITS TS, 4

-AFW 3.6.5 <

3.6' PLANT SYSTEMS

-3.6.5 . Auxiliary Feedwater System $

f LC0 3.6.5 Three steam generator Auxiliary Feedwater-(AFW) pumps-and.

  • their associated flow paths shall._ be OPERABLE.

' APPLICABILITY:' MODES l', 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One'AFW pump-inoperable. A.1 Restore AFW pump to- -72 hours b OPERABLE status.

  • L B. Two AFW pumps- B.1 Be in MODE 3. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />s-inoperable.

D.B -

B.2 Be in MODE 4. '

Required Action for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

l. Condition-A not met l within required-Completion Time.

l- (continued)

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North Anna Units 1 & 2 3.6-9 Amendment Nos. xxx & yyy

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AFW .!

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3.6.5'

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~ ACTIONS- (continued)

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CONDITION REQUIRED ACTION: COMPLETION TIME i C. Three AFW pumps ----------NOTE----------

inoperable.  :

LCO 3.0.3 and all other-- '

LCO Required Actions  ;

requiring MODE changes are suspended until at least one AFW pump is O restored to OPERABLE status.

C.1 Initiate action to 15 minutes .,

restore one AFW pump to OPERABLE status.

C.2 Continue action as Until one AFW required in C.I. , pump is restored to OPERABLE status SURVEILLANCE _ REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify each motor-driven AFW pump's As specified developed head at the flow test point is by SR 3.0.5 2 the required developed head.

SR 3.6.5.2 -------------------NOTE-------------------

l SR 3.0.4 is not applicable for entry into i

MODE 3.

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l Verify the turbine-driven AFW pump's As specified developed head at the flow test point is by SR 3.0.5 2 the required developed head.

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North Anna Units 1 & 2 3.6-10 Amendment Nos. xxx & yyy

4 AFW 3.6,5 i

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SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

-SR 3.6.5.3 Verify each AFW manual, power-operated, 31 days and automatic valve (excluding check g valves) in the flow path, that is not locked, sealed, or otherwise secured in position, is in its correct position.

q SR 3.6.5.4 Verify each automatic valve (excluding 18 months-p check valves) actuates to its correct E position on an AFW actuation signal.

L L SR 3.6.5.5 Verify each AFW pump starts automatically 18 months

on an AFW actuation signal.

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l SR 3.6.5.6 Verify required AFW flow paths by flowing -----NOTE-----

to each steam generator. Only required l for units that p do not use AFW l -system for L Startup/

Shutdown I

operations Prior to entering MODE 2, whenever unit has been in MODE 5 for

> 30 days CROSS-REFERENCES TITLE NUM8ER l

Containment Integrity 3.5.1 l North Anna Units 1 & 2 3.6-11 Amendment Nos. xxx & yyy l

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.a 6-2-81

~ PLANT SYSTEMS- l

. AUXILIARY FEEDWATER SYSTEM LIMITING '"ITION FOR OPERATION L

3.7.1.2 At least three independent steam generator auxiliary feedwater' pumps y and associated flew paths shall be OPERABLE with:

.a. Two motor driven auxiliary feedwater pumps, each capable of being powered from separate emergency busses, and .

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b. . One. steam turbine driven auxiliary feedwater pump capable-of being l

powered from an OPERABLE steam supply system.-

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? APPLICA81LITY: IWOES.1, 2 and 3.

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a. With one auxiliary feehater pump inoperable, restore the required auxiliary feedwater pueps to an 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 1

NOT SHUT 00WN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

1.

2 h b. With two auxiliary feedwater pumps inoperable be in at least' HOT = STAdD8Y .

within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and 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 />, l-

c. With three auxiliary feedwater pumps inoperable, immediately initiate corrective action tu .'estore at least one cueiliary feedwater pump to OPERABLE status as soon as possible.

! SURVEILLAEE REQUIREMENTS M? . 7.1. " In .441tien te it 7%.is -- ate ef ';nificetien t.0.;, ..eh* auxiliary feedwater pumps shall be demonstrated OPERABLE / 4ouj htwM 40 Sput.ted:en 4.o.s. ,

L TL. petes. ens o4 Spu.hh 00 i 9 ore. nw cxppy.c.ge. +e shea ck.w.n puq -\ cran).

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1. "rtigia;; tr.et ee;t ;;eter driver. ;- dev;1epe e diech.rv.

er;r :r. ef si.eter tr.en er e-;-eal te 1200 peig .i e flow of I

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7 ..;; er 5-; Eel te 0; w .

t 2. "eriffia; tret tre et:x t.rtire driven p ;p seveiepe e die =

e:: ,; ;r; n ;r:-ef ;7;;tr t' er ;; :1 te 1"" pe19 i . ile-ef ; at:r t'.;  : = 1 te 25 .,- er, re;ireeletion ilow. The p

pie.ietene ef ',p.eifieetien 0.0.t ere ist .vyli6. Liv.

l Tcedder sub:yAtm "d%\\ be-Li,9,\,'A Each decnn e.nercAor Guxl.\.

demonsN< dea. 9EMtts by.

NORTH ANNA - UNIT 1 3/4 7-5 Amendment No. 32 l-l r.

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6-2-81 PLANT SYSTEMS SURVE!LLANCE REQUIREMENTS (Continued)

RN least onv }v :Ttdap b jl.-IVerifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise-

secured in position, 1s.in its correct position.-

c f. ' At least once per 18 months during shutdown )$:

1. Verifying that each automatic valve in the flow path actuates to its correct position on an auxiliary feedwater actuation test 28 signal.
2. -Verifying that each auxiliary feedwater pump starts automatically upon receipt of an auxiliary feedwater actuation test signal.

The auxiliary feedwater system'shall be demonstrated OPERA 8LE prior el /. to entry into M00E 3 following each COLD SHUT 00WN by performing a flow test to verify the normal flow path from the emergency condensate storage tank through each auxiliary feedwater pump to its associated steam generator.

NORTH ANNA - UNIT 1 3/4 7-6 Amendment No. 32

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f 8-21-80

( PLANT SYSTEMS AUXILIARY FEEDWATEli SYSTEM LIMITING CONDITION

  • FUR OPERATION '

3.7.1.2 At least three independent steam generator auxilfary feedwater pumps and associated flow paths shall be OPERABLE with; a.- Two estar driven auxiliary feedwater pumps, each capable of being powered from separete emergency busses, and

b. One steam turnine driven auxiliary feedwater pump capable of being powered from en OPERA 8LE steam supply systas.

AP1 LEA 81LITY: M00E3 1, 2 and 3.

  • MD1@:
a. -

With one auxiliary feedwater pump inopernele. restore the recuired' auxiliary feedwater pumps to a OPERA 8LE 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 following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. With two auxiliary feedwater pumps inoperable be in at least HOT STAN08Y z within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> anc in HOT SHUTDOWN within the following 6' hours.
c. With three auxiliary feedwater pumps inoperable, immediately initiata corrsetive action to restore at least one auxiliary fasewater pump to CPEAA8LE status as soon as possible.

SURVEILLANCE REQUIREMENTS 4.7.i.i in dsiii.n i,. in. . 4.i . _ ate ef Si;eeifi;;;ien ?. 0. 5, ;;;r.^ auxiliary e demons pursund +o S

.%.p<uuomossp.

feedwater pumps shall o.s gwuen cve nas.trated oppm CPERA8LE/ %se.  % w,,, y,,y.du, h

.. 't lee;0 ;;;; p;r 31 day; by+-

, D9 4,g;,D,

1. Verifjing that ;;;n 0;ter driv;; p;.:::c d;;;i;;; ; di;;n;r;;-

pr;;; r. ;f ar;;;;r tt;n er ;; eel ;; 12f,0 ;;;is et e flew ef gr;;. ;r then er eq.&1 te 53 @e.

2. Y;rif fing th;; the ste;.; tortine dri..n yo p 4.v. ivy. . dir
7.;rge pre;;ere of sieeter then er eqwel te 1340 piig et e flew ef greater tr.er er egeel ;&
: ;;;.; ;n re;ir;.;1&ti;n fin. The

. ;r.vi;i;;; ef !;;;ifi;etien 0.0.4 ere net epplicesie.

Ql.\. A Eoch sb }enusAor OuxWu] Th\er 95p% thw be de%;ccaes OfENtE bi NORTH ANNA - UNIT 2 3/4 7-5 1

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4 8-21-80 R pl#T $Y$ tdt $

$URVE!LLANCE Rt00!REMENTS (Continued)

RV \ tom once. per 3\ .d ays b j.- Verifying that each valve (aanval, power operated' or automatic) in the flow path that is not locked, sealed,' or otherwise secured in position, is _in its correct position.

c, f. -

At least once per 14 months during shutdown g ,

1. Verifying that each automatic valve in the flow path actuates -

to its correct position on an auxiliary feedwater actuation test signal.

2.- Verifying that each auxiliary feedwater pump starts automatically

=upon receipt of an auxiliary feedwater actuation test signal.

~ d /. The auxiliary feedwater systes shall be demonstrated CPEAA8LE neier -

t to entry into MODE 3 following each COLD SHUTDOWN by performing a- -

'- flow test to verify the normal flow path free the emergency-condensata storage tank through each auxiliary feedwatee pump to its associated steam generator. -

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NORTH ANNA - UNIT 2 3/4 7-6

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. -.5 Attachment 2 Safety Evaluation

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k-Discussion of Pronosed Technical Snecification Change Introduction

. The proposed change to North Anna Units 1 and 2 Technical Specification 4.7.1.2 deletes the 31 day test frequency for the auxiliary feedwater pumps but retains reference to Section XI of the ASME Code which requires quarterly testing.

The reduced testing frequency will not reduce pump reliability, Rather, safety will be enhanced because the monthly test, which is done at a flow rate below the design flow, has been found to degrade the pumps.

Background

NRC Bulletin 88-04: " Potential Safety-Related Pump Loss" identified concerns with minimum flow designs of safety related pumps and requested licensees to investigate these concerns and correct them where applicable. Virginia Electric and Power Company responded to these concerns in a letter to the NRC on August 8,'1988 (Serial No.- 88-2758). As part of the response we committed to disassemble and inspect the Auxiliary Feedwater Pumps at North Anna Power Station for any signs of -

degradation. The inspection schedule was to be one pump per unit per outage, with any signs of degradation resulting in immediate inspection of the other pumps on the affected Unit.

As a result of initial inspections performed on both Units during the 1989 refueling outages, all six pumps were disassembled and inspected. Numerous problems were discovered, including diffuser vane cracks, scored bearings, and tolerances out of specification. A root cause evaluation attributed part of these problems to the way in which the pumps are tested. The pumps were not designed to run on recirculation for long periods of time, which is the current practice. During the recirculation mode of operation, the recirculation line orifice restricts flow to less than 20% of best efficiency point flow. The pumps experience increased vibration and axial thrust, which in turn leads to increased wear.

Several engineering studies to correct this problem have been undertaken (see attached reference list). Their recommendations have consistently addressed both design deficiencies and test frequencies as major contributors to pump degradation.

To minimize future pump wear and ensure long term reliability of the auxiliary feedwater pumps, several courses of action are being pursued:

+ Minimize operation of the pumps at low flow. This includes limiting use of the pumps for steam generator leak testing, revising procedures for the quarterly ASME test and applying for a Technical Specification change to eliminate the requirement for a monthly test on recirculation flow.

  • Install a larger recirculation line.

Change the design of various mechanical components. This includes reducing the use of cast iron and improving lubrication.

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Descrintion of the Pronosed Chance

1. A new sentence is added before the existing 4.7.1.2 Specification: "4.7.1.2 Each steam generator auxillary feedwater subsystem shall be demonstrated OPERABLE by;"  ;
2. The existing "4.7.1.2" is replaced by "a". .
3. The phrase "In addition to the requirements of Specification 4.0.5, each auxiliary feedwater pump shall be demonstrated OPERABLE" is replaced by " Testing the auxiliary feedwater pumps pursuant to Specification 4.0.5. The provisions of Specification 4.0.4 are not applicable to steam driven pump testing." The exclusion of Specification 4.0.4 from steam driven pump applicability is not new, it ,

was in 4.7.1.2.a.2 which is to be deleted.

4. Existing sections 4.7.1.2.a,4.7.1.2.a.1 and 4.7.1.2.a.2 are deleted.
5. Existing section 4.7,1.2.a.3 is changed to 4.7.1.2.b and the phrase "At least once per 31 days"is inserted in front. The "31 day" modifier for the new 4.7.1.2.b (valve line up verification) is inserted because of the 4.7.1.2.a deletion.
6. The labels for 4.7.1.2.b and c are changed to c and d.
7. The word "by" in the new 4.7.1.2.c after "during shutdown" is deleted.

Safety Analvsis The change deletes the surveillance requirement to demonstrate at least every 31 days that the pumps can develop at least 1250 psig at 53 gpm for the motor driven >

pumps and at least 1380 psig at 35 gpm for the turbine driven pump. The test is done by pumping through an orificed recirculation line at a flow rate far below the design parameters. The current Specification test conditions (pressure and flow) require that the tests be performed in the recirculation mode of operation.

L The proposed change retains the requirement that the pumps be tested in accordance L with Specification 4.0.5, which refers to Section- XI of the 1980 ASME Boller and Pressure Vessel Code. The Code requires testing every three months. The tests include measurements of the inlet pressure, differential pressure, flow rate, vibration amplitude, speed of the turbine driven pump and observation of lubricant level or pressure. The first test when the pumps are new or overhauled is used to establish reference data. The Code defines acceptable ranges for these parameters which are functions of the reference data. Outside the acceptable range is an " alert range." The Code requires the test frequency to be doubled if any parameters are in the alert

! range. Beyond the alert range is the " required action range." If any parameters are in L this range, the pump is declared inoperable. Reference parameters were originally l

established using the orificed recirculation lines. The current T.S. values are based on these tests. Because the pumps were recently overhauled, new reference ASME data has been established. The new parameters were obtained by pumping to the steam generators at a much greater flow rate. The new test procedure minimizes the time on l recirculation flow to the time required to obtain T.S. required data. ASME required i

l data is obtained at a flow close to design best efficiency point flow. Obtaining data at this point is much more meaningful for pump performance assessment.

Changing the testing frequency of the auxiliary feedwater pumps to quarterly will serve to reduce the wear on pump internals and increase overall reliability of the pumps.

- The present configuration for testing the pumps involves a low flow recirculation path.

This fact, combined with continued monthly testing, is expected to result in long term pump wear, as evidenced by the recent onsite inspections. The decreased testing frequency will result in lower wear' rates and increased long term pump reliabifity.

Because the auxiliary feedwater pumps fall under the jurisdiction of the ASME Section XI testing program, the pump testing frequency will automatically double should any indication of pump degradation arise. Experience has shown that recent pump degradation occurred over a long period of time. Tracking the pumps' performance under the Section XI IWP program will provide ample opportunity to detect anomalies or variations in pump performance, and will allow ample opportunity to take corrective actions when needed. Since the pumps are not run routinely and not used for startup, (most of the run time is used for testing) no degradation between tests is expected.

The recent overhaul of the pumps allowed the opportunity to establish solid baseline data on which to compare future results.

Despite the deficiencies found on these pumps during recent inspections, the auxiliary feedwater pumps have proven themselves to be reliable. The testing history for these pumps indicates that performance has been adequate, mum

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.- 1 References

1. Mechanical Engineering Report No. ME 0023, Auxiliary Feedwater Pump Technical Specification Change Request for North Anna Power Station, Rev 0, August 1989.

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-: 2. NAPS Technical Report No. SE-002, Evaluation of Auxiliary Feedwater Pumps, Rev 0, April 1989.

L 3. NAPS Technical Report No. SE-002, Addendum No.1, Evaluation of Auxiliary b Feedwater Pumps, July 1989.

4. Memorandum from R. W. Riley to Distribution, June 22,1989,

Subject:

NP-2051, Auxiliary Pump System Upgrade.

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Attachment 3 10 CFR 50.92 Evaluation 1,;;

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... nf-LBasis for No Significant Hazards Determination The proposed change does not involve a significant hazards consideration as defined -

in 10 CFR 50.92 because operation of Nonh Anna Units 1 and 2 in accordance'with this change would not: -

(1)- Involve a significant increase in the probability or consequence of an accident previously evaluated. This change does not alter the conditions or assumptions of the accident analysis or the basis of the current Technical Specification. The consequence of an auxiliary pump failure is unchanged. The probability of such a failure is actually reduced because a source of pump degradation is minimized.

(2) -create the possibility of a new or different kind of accident from any accident previously identified. :This change does not alter the conditions or assumptions of the accident analysis or the basis of the current Technical Specification. This is not an actual hardware change.

(3) involve a significant reduction in a margin of safety. This change does not

. alter the conditions or assumptions of the accident analysis or the basis of the current Technical Specification, it is not an actual hardware change.

Therefore, pursuant to 10 CFR 50.92, based on the above considerations, it has been determined that this change does not involve a significant hazards consideration.

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