ML20012C573

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Proposed Tech Spec 4.5.2,modifying Existing Surveillance Requirements for Venting of ECCS Equipment & Reducing Significant Exposure to Radiation in Accordance W/Alara Guidelines W/O Reducing Safe Operation of ECCS Equipment
ML20012C573
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 03/17/1989
From:
COMMONWEALTH EDISON CO.
To:
Shared Package
ML20012C548 List:
References
NUDOCS 9003220220
Download: ML20012C573 (8)


Text

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s AIIACIMMI_A ERQEQSED CHANDES TO AEfj;NplK_4 IgcgICAL SPECIUChTIONS OF FACILLH OPERATING LICQlRES NPF-37 NPF-66. NPF-72 ansLEPM i

i SyLQn_$_(ation RIaldwood Station' 1'

Revised Page: 3/4 5-4 3/4 5-4 i !

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EMERGENCY CORE COOLING SYSTEMS

- 1 SURVEILLANCE REOUIREMENTS J

<tl 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a.

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At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following valves '

are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position MOV SI8806 Suction to the SI Open Pumps

'MOV SI8835 SI Pump Discharge Open*

To RCS Cold Legs . I-MOV SI8813- SI Pump Recirculation Open-

.To The RWST MOV SIB 809A RHR Pump Discharge to RCS Cold Legs Open* d MOV S18809B RHR Pump Discharge to Opn a .f RCS Cold Legs MOV SIB 840 RHR Pump Discharge to Closed RCS Hot Legs MOV SIB 802A SI Pump Discharge to Closed RCS Hot Legs MOV SIB 802B SI Pump Discharge to Closed RCS Hot Legs

b. once per 31 days by: 1
1) -Verifying ECCS pump casings an CCS piping is full of water by venting the  ;

"le dh t rge piping high points, and  ;

2) Verifying that each valve (manual, pow in the flow path that is not locked, sealed, or oted, or automatic)

secured in position, is in its correct position. i c.. ,

By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump be suctions during LOCA ebnditions. This visual inspection shall performed:

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" Valves may be realigned for testing pursuant to Specification 4.4.6.2.2.

-P BYRON - UNITS 1 & 2 3/4 5-4 AMENDMENT NO.

' EMERGENCY-CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS

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4.5.2 Each ECCS' subsystem shall be demonstrated OPERABLE: i

a. At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that' the following valves  !

are in th% indicated positions with power to the valve operators -

removed:

Valve Number Valve Function Valve Position.

MOV SI8806 Suction to the SI Oper. I Pumps MOV SIB 835 SI Pump Discharge Open*  ;

To RCS Cold Legs  !

r M0V SI8813 .SI Pump Recirculation Open To The RWST MOV S!8809A RHR Pump Discharge to Open* ,,

RCS Cold Legs MOV SI8809B RHR Pump Discharge to Open*

RCS Cold Legs i MOV SIB 840 RHR Pump Discharge to Closed  ;

RCS Hot Legs j

MOV SI8802A SI Pump Discharge to Closed l RCS Hot Legs. '

MOV 5I88028 SI Pump Discharge to Closed RCS Hot Legs

b. At ce per 31 days by:
1) Verifying tha CCS piping is full of water by venting the i ECCS pump casings and a le discharge piping high points, and -
2) Verifying that each valve (manual, po ated, or automatic) i in the flow path that is not locked, sealed, or ise  ;

secured in position, is in its correct position.  !

c. By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be  !

transported to the containme.nt sump and cause restriction of the j pump suctions during LOCA conditions. This visual inspection shall ~

be performed:

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  • Valves may be realigned for testing pursuant to Specification 4.4.6.2.2.

BRAIDWOOD - UNITS 1 & 2 3/4 5-4

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L-N INSERT TO PAGE 3/4 5-4 1

b. 1) By verifying thatt e

a) The discharge piping for the ECCS subsystem. required by f

Specification 3.5.3 is full of water, by venting the ECCS discharge piping hlgh points, prior to entering MODE.4 from MODE.5, if venting has not been performed in the-previous 31 days, and

~ e-b) The discharge piping for both ECCS subsystems is full of '

water, by venting the ECCS discharge piping high points, l:.

prior to entering MODE 3 from MODE 4, if venting has not been performed in the previous 31 days.

2) At least once per 31 days by: I a) Verifying that the ECCS suction plping is full of water by venting the ECCS pump casings, and b) Verifying that each valve (manual, power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct.

position.

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ATTACl! MENT D DESfElEIlON AND

SUMMARY

_Qf_.PfQfQSED CilANGES The present Technica1' Specification 4.5.2 regulres all ECCS piping to be verlfled full of water by venting every 31 days. This requirement requires entry into several High Radiation areas during power operation which provides a significant impact on plant operations. The vents located on the discharge portion of the ECCS piping are-located inside containment, thus involving substantial radiation exposure to individuals: performing the I: surveillance. The proposed change will assist in reducing this exposure #

consistent with ALARA guidelines, and at the same time, provide an j-_ equivalent means of performing the necessary surveillance.

The proposed amendment to Technical Specification Surveillance

{ ;- Requirement 4.5.2.b would- require that the ECCS discharge,, piping bo demonstrated operable by venting It prior to entry into Mode 4 for the operable single train, and prior to entry-into Mode 3 for both operable trains. . These surveillance requirements will be performed when venting has not been completed in the previous 31 days.

The surveillance for- the ECCS auction _ piping and the ECCS pumps will continue to be done on the once per 31 day frequency. Since this equipment is located outside contaimnent, radiation exposure is not as significant.

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ATTACm4ENT C SAFETY EVALUATION AND Et[YJJONMENTAL ASSESSMENT The revised ECCS pipe venting survellisnee requires venting of discharge piping prior to entering Mode 3 or 4, as required. This approach should ensure that no air pockets exist following plant evolutions that might result in the ECCS piping being drained or opened to atmosphere.

Af ter entering Mode 3 or 4, manipulations should not occur that wouldL result in gas volds being introduced. Since pump casing and suction piping will be.

vented monthly, the full condition of the ECCS will be routinely verified.

These venting procedures should ensure the ECCS piping is adequately filled prior to entering Mode 3 or 4 and subsequently maintained in that condition. Also, all ECCS piping up to the Reactor Coolant System is- s physically located at a lower elevation than the Refuel Water Storage Tank.

This be.Ing the case, all piping would be maintained at a pressure greater than atmospheric. This provides assurance that the piping will remain full at all times.

Commonwealth Edison has evaluated the proposed amendment against

'the' criteria-for and identification of licensing and regulatory actions requirj ug environment assessment in accordance with 10 CFR 51.21. It has been determined that the proposed change meets the criteria for a categorical exclusion as provided'for under 10 CFR 51.22(c)(g). This determination was based on-the fact that.this change is being proposed as an amendment to a license issued pursuant to 10 CFR 50. The change involves no significant hazards, there is no significant change in the types or amounts of .of fsite ef fluents, and there is no significant increase in individual or cumulative occupational radiation exposure.

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I 1 s ATTACHtiENT_p UAW AT LVli_ Q[_31 CN 1 f 1 C ANI.j{ AgMQjl CQN U DJ Rh710K$

Commonwealth Edison has evaluated this proposed anendment and determined that it involves no significant hasards considerations.

According to 10 CTR 50.92(c), a proposed amendment to an operating license involves no significant hasards considerations if operation of the facility in accordance with the proposed amendment would nott

1. Involve a significant increase in the probability or consequences of an accidvnt previously evaluated
  • or
2. Create the possibility of a new or alfferent kind of accident from any accident previously evaluated or

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3. Involve a significant reduction in a margin of safety.

A. Tht.P.IR22E23 chaDgt_dQ1R_nat_intQ1Yt A.E.lgnificant_Jngt.tast. An ..thm p.Tchab.i.1117..nt.Innstgnentts Af_an_attidaut PLeviqua1y..e3Ainated.

The probability of an accident occurring is independent of any testing requirements. No changes to the CCCS system are being made that would increase the probability for en accident, nor affect an initiating event of an accident. The revised testing provides assurance that the ECCS piping will remain in a full condition.

Venting will be performed after achieving cold shutdown, if venting has not been not performed in the previous 31 days. Venting will also be performed on piping after any maintenance activity that has the potential to drain the piping. This approach comblned with the fact that the piping by design remains above atmospheric pressure at al', times, provides assursnce that the piping will remain fir.ed, and the system will be capable of providing injection flow dthin all assumed time responses.

B. Tht ptQpoind.shangt JQt1_rs1_EtzAtt_.the w PSAsibill.tk.nLt_nex QI different k,lnd of accident from aDy ACIIAtal.previously 11&lukLtd.

No new equipment is being introduced that could create a new kind of accident. No changes are being made to existing equipment.

Presently, installed equipment will continue to be operated within the bounds of the UTSAR.

C. The..PLQPnard_ChAngt 3015 Dat iDER 1 ve a signiLicant.rtdvCtlan_in _m mBLgin of saltiy.

The revised venting surveillance requirements provide adequate assurance that the ECCS piping will be maintalued in a filled condition. By maintaining the ECCS piping filled, delivety M water to the core in the event of an accident will temain unchanged. The revised ECCS pipe venting surveillance will not reduce the capability of the ECCS to function as described in the Bases for 3.5.2 and the Byron /Braidwood UTSAR. As such, the proposed changes do not involve a significant reduction in a margin of safety.

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Therefore.,basodion the above evaluation, Commonwealth Ediron- -

i k, 'T believes that these changes'do not involve significant hasards- '

M.N, ;. consideration. ..

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