ML20006C761

Requests Discretionary Enforcement Applied to Tech Spec to Allow Unit to Remain in Mode 3 to Facilitate Performance of Required Testing

ML20006C761
Person / Time
Site:	Seabrook
Issue date:	01/09/1990
From:	Feigenbaum T PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20006C758	List: ML20006C761
References
NYN-90007, NUDOCS 9002090105
Download: ML20006C761 (3)

Text

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Homoshira

r. Ted C. Feigenboum" m '

Senior Vice President and - i

_ _ _ _ _ Chief _ Operating Officer I.

). NYN- 90007  ;

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,;e. 1 A January 9. 1990 A . United States Nuclear Regulatory Coasaission 1 Region I .

p -475 Allendale Road. .

f. : King of Prussia. PA 19406 c  ;

Attention: Mr. William T. Russell, Regional Administrator i

Reference:

' Facility Operating License NPF-67. Docket No. 50-443 1

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. Subjects : Request for Discretionary Enforcement t Gentlemen New Hampshire Yankee will be performing post-modification testing on '

the Seabrook Station-steam turbine-driven emergency feedwater (E N) pump during preparation.for power. ascension testing. .The post-modification testing to be performed for this E W pump is described in Enclosure 1.

'Seabrook Station Technical. Specifications allow entry into MODE 3 to perform surveillance testing,for the steam turbine-driven EN pump, and  ;

allow this pump to be inoperable for up to. 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; New Hampshire Yankee

-. intends =to perform a more comprehensive-pre-operational test (STP-121)'

-rather.than the normal ~ post-modification test in-order to demonstrate . total system operability. New Hampshire Yankee ^hereby requests that discretionary enforcement be applied to this- Technical Specification-to allow the- unit to ,

. remain in MODE 3 to facilitate the performance of the-required' testing.  ;

Specifically. New Hampshire Yankee requestsLthat discretionary enforcement

-.be applied for two to three days, if necessary, subsequent to the expiration of-the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. time restriction in Technical Specification 3.7.1.2, to l

' facilitate a carefully controlled, high quality test. New Hampshire Yankee l'

.will promptly inform the NRC both,upon initiation and expiration of the discretionary' enforcement period.

The performance of~this testing in MODE 3 does-not create the I g

-possibility of any adverse safety consequences. During this testing, the' ,

,L.ro. unit will.be suberitical with negligible decay heat. Although the steam 'l QM turbine-driven E W pump is considered to be INOPERABLE during the period of j g.~ ~ time it is being tested, the proposed change applies only to stable shutdown a 40 -

on ' conditions where the two motor-driven auxiliary feedwater pumps (the startup

' feed pump and the motor-driven EFW pump), are OPERABLE'and the plant is l jL preparing for a startup with negligible decay heat, rather than performing a  !

-o- cooldown under emergency conditions. Furthermore, the operability of the l M two motor driven pumps is ensured through the mode change administrative controls, Procedure OP 11.4, "Mooc Change Notice". Prior to authorizing I

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New Hampshire Yankee Division of Public Service Company of New Hampshire l P.O. Box 300

• Seabrook, NH 03874

• Telephone (603) 474 9521 ,

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United States Nuclear Regulatory Commission January 9, 1990-Attention Mr. William T. Russell Page 2  ;

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. l entry into Mode 3, the Shift Superintendent must verify the completion of- j the necessary surveillance requirements, including those applicable to the  ;

motor driven EFW and the startup feedwnter pumps. )

If you have questions regarding this request, please contact l Mr. Terry L. Harpster, Director of Licensing Services,_at (603) 474-9521, l extension 2765. .

l Very truly yours, 1

f.dth AfW Ted C. Feigenbaum cc: Document Control Desk United States Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Victor Nerses Project Manager Project Directorate I-3 United States Nuclear Regulatory Commission Division of Reactor-Projects ii Washington, DC 20555 NRC Senior Resident Inspector P.O. Box 1149 Seabrook, NH 03874

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ENCbOSURE TO NYN-90007 BACKGROUND New Hampshire Yankee has modified the Seabrook Station Auxiliary Feedwater System to resolue concerns regarding valve leakage and reliability for three valves in the steam supply system for the steam turbine-driven emergency feedwater (EFW) pump. This modification includes the replacement of the previously installed 4-inch Hammel-Dahl valves with 4-inch Hasonellan a valves utilizing 3-inch internal trim for smoother-flow control. This valve configuration will ensure positive actuation of the valves. Additionally,  !

the Woodward governor for the turbine has been modified by replacing the acceleration bushing in order to smooth turbine acceleration on demand. New

~ Hampshire Yankee intends to perform comprehensive pre-operational testing.on the steam turbine-driv'en EFW pump prior to entry into MODE 2.

DESCRIPTION OF TEST The testing.to be performed involves six etarts of the steam turbine-driven EFW pump. The first start will be a manual start of the pump to verify the-proper functioning of the modified governor. Following this start, five cold starts of the system will be performed. After each start, the piping will be allowed to cool until the temperature at a monitoring point.is less- ,

than 140 Fahrenheit (approximately six hours). The testing will be. [

performed in the following sequence: 1) actuate both steam supply trains,

2) actuate the A steam supply train only, 3) actuate the B steam supply train only, 4) actuate.both steam supply trains, and 5) repeat actuation of both steam supply trains. During the performance of this test, it is anticipated that minor changes, such as adjustment of valve timing, may be required.

New Hampshire Yankee believes that the performance of this comprehensive testing will result in a level of assurance of system operability equivalent to or greater than that achieved by previous system testing (ST-53 and STP-101).

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