ML20052B484
| ML20052B484 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/28/1982 |
| From: | Broehl D PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20052B473 | List: |
| References | |
| RTR-NUREG-0452, RTR-NUREG-452 NUDOCS 8204300481 | |
| Download: ML20052B484 (12) | |
Text
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PORTLAND GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY TROJAN NUCLEAR PLANT I
Operating Licerise NPF-1 l
Docket 50-344 l
License Change Application 26, Revision 2 i
l l
This License Change Application requests modification of Technical Specifications contained in Appendix A to Operating License NPF-1 regarding In-Service Testing of pumps and valves pursuant to Section XI of the ASME Boiler and Pressure Vessel Code.
PORTLAND GENERAL ELECTRIC COMPANY By 17/
~
/ Donald J. Brdeh1 Assistant Vice President Nuclear l
l Subscriber' and sworn to before me this 28th day of April 1982.
OMyCommissio 2-i n /
e 1
Notary Public of Orggon i
(tw rc,, / f /[M l
82043004
)
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s LCA 26, Ravicien 2 Page 1 of 11 i
The proposed replacement pages to Appendix A of Facility Operating License NPF-1 are provided as Attachment 1.
A description of these changes follows.
j 1.
Page 3/4 0-2 (and 3/4 0-3): Acted on in Amendment 61.
2.
Pages 3/4 1-7 through 3/4 1-10:
a.
Delete Item 1 of Specification 4.1.2.1.a, and combine Item 2 with opening phrase, to read as follows:
"a.
At least once per 7 days by verifying that the temperature of the flow path is 2,65'F when a flow path from the boric acid tanks is used."
b.
Add a new Subsection 4.1.2.1.c as follows:
"c.
By verifying that each power operated or automatic valve in the flow path is OPERABLE when tested pursuant to Specification 4.0.5."
c.
Delete Item 1 of Specification 4.1.2.2.a and combine Item 2 with the opening phrase to read as follows:
"a. At least once per 7 days by verifying that the temperature of the flow path from the boric acid tanks in >65'F."
d.
Add a new Subsection 4.1.2.2.c as follows:
l "c.
By verifying that each power operated or automatic valve in the flow path is OPERABLE l
when tested pursuant to Specification 4.0.5."
e.
Redesignate the existing Subsection 4.1.2.2.c as 4.1.2.2.d, delete Item 1 of the renumbered subsection, and combine it with Item 2 with the opening phrase to read as follows:
l "d.
At least once per 18 months, during shut-l down, by verifying that each automatic valve in the flow path activiates to its correct position on a safety injection test signal."
3.
Page 3/4 1-11: Change Specification 4.1.2.3 to:
l "4.1.2.3 The above required charging pump shall be l
demonstrated OPERABLE by verifying, that on recirculation flow, the pump develops a discharge pressure of 2,2400 l
psig when tested pursuant to Specification 4.0.5."
i i
i L
s LCA 26, Rrvisicn 2 Page 2 of 11 4.
Page 3/4 1-12:
Change Specification 4.1.2.4 to:
"4.1.2.4 At least two charging pumps shall be demon-strated OPERABLE by verifying, that on recirculation flow, each pump develops a discharge pressure of
>2400 psig when tested pursuant to Specification 4.0.5."
5.
Page 3/4 1-13:
Change Specification 4.1.2.5 to:
"4.1.2.5 The above required boric acid transfer pump shall be demonstrated OPERABLE by verifying, that on recirculation flow, the pump develops a discharge pressure of >105 psig when tested pursuant to Specification 4.0.5."
6.
Page 3/4 1-14:
Change Specification 4.1.2.6 to:
"4.1.2.6 The above required boric acid transfer pump shall be domonstrated OPERABLE by verifying, that on recirculation flow, the pump develops a discharge pressure of >105 psig when tested pursuant to Specification 4.0.5."
7.
Page 3/4 4-4:
a.
This change request has been deleted in Rev. I to LCR TNP-79-01.
b.
Change Specification 4.4.3 to:
"4.4.3 No additional Surveillance Requirements other than those required by Specification 4.0.5."
8.
Page 3/4 4-6: Acted on in Amendment 61.
9.
Page 3/4 4-7: Acted on in Amendment 61.
10.
Page 3/4 4-8: Acted on in Amendment 61.
11.
Page 3/4 4-9 and 3/4 4-9a: Acted on in Amendment 61.
12.
Page 3/4 4-29: Acted on in Amendment 61.
13.
Pages 3/4 4-30 through 3/4 4-49: Acted on in Amendment 61.
14.
Pages 3/4 5-4 through 3/4 5-6a: Make the following changes to Specification 4.5.2:
a.
Specification 4.5.2.b:
(1) Delete "on a STAGGERED TEST BASIS" in the introductory sentence and delete Specifications 1, 2, 3 and 4.
L-
3 LCA 26, Rtvisien 2 Page 3 of 11 (2) Combine old Specification 5 on Page 3/4 5-5 with the introductory phrase of this Specification on Page 3/4 5-4.
b.
Delete Specification 4.5.2.c and redesignate Sections 4.5.2.d, e, f, g, and h as Sections 4.5.2.c, d, e, f, and g, respectively.
c.
Add a new Subsection 4.5.2.h as follows:
"h.
By verifying that each power. operated or automatic valve in the flow path is OPERABLE when tested pursuant to Specification 4.0.5."
d.
Add a new Specification 4.5.2.1 as follows:
"1.
By verifying that each of the following pumps develops the indicated discharge pressure on recirculation flow when tested pursuant to Specification 4.0.5:
1.
Centrifugal charging pump >2400 psig.
2.
Safety injection pump 2;1455 psig.
3.
Residual heat removal pump 2; 165 psig."
15.
Page 3/4 6-10:
Change Specification 4.6.2.1.a to:
a.
"a.
By verifying, that on recirculation test line flow, each pump develops a discharge pressure of 2,228 psig at a flow of 2,586 gpm for FE-2066 and 2,227 psig at a flow of 2,592 gpm for FE-2067 when tested pursuant to Specification 4.0.5."
b.
Delete old Specifications 4.6.2.1.a.1 through 4.
I Redesignate old Specification 4.6.2.1.a.5 on Page 3/4 6-11 c.
as 4.6.2.1.b and add at the beginning:
"At least once per 31 days by...".
16.
Page 3/4 6-11:
Redesignate old Specification 4.6.2.1.b as 4.6.2.1.c.
a.
b.
Delete old Specification 4.6.2.1.b.1 (new Specification 4.6.2.1.c.1) and renumber remaining specifications accordingly.
c.
Redesignate old Specification 4.6.2.1.c as 4.6.2.1.d.
s s
LCA 26, Revision 2 Page 4 of 11 d.
Add a new Subsection 4.6.2.1.e as follows:
"e.
By verifying that each power operated (excluding automatic) valve in the flow path is OPERABLE when tested pursuant to Specification 4.0.5."
17.
Page 3/4 6-12:
In Specification 4.6.2.2.a. delete Item 1 and include Item 2 in one sentence beginning with heading of a.
18.
Page 3/4 6-13:
a.
In Specification 4.6.2.2.c, delete Item 1 and combine Item 2 with heading of c.
b.
Add a new Subsection 4.6.2.2.e as follows:
"e.
By verifying that each power operated (excluding automatic) valve in the flow path is OPERABLE when tested pursuant to Specification 4.0.5."
19.
Page 3/4 6-15:
In Specification 4.6.3.1.1:
a.
Delete Item a.
h.
Combine Item b with the beginning sentence of 4.6.3.1.1, delete the words "immediately" and "above", and replace the word "the" in the last line, to read as follows:
"4.6.3.1.1 The isolation valves specified in Table 3.6-1 shall be demonstrated OPERABLE prior to returning the valve to service after main-tenance, repair or replacement work is performed on the valve or its associated actuator, control or power circuit by performance of a cycling test and verification of isolation time."
20.
Pages 3/4 6-16 and 3/4-6-22:
In Specification 4.6.3.1.2, delete Items e and d.
a.
b.
Delete old Specification 4.6.3.1.3 and replace with the following:
"4.6.3.1.3 The isolation time of each power operated or automatic valve of Table 3.6-1 shall be determined to be within its limit when tested pursuant to Specification 4.0.5."
c.
In Table 3.6-1 on page 3/4 6-22, change "no" to "yes" under the column heading " Testable During Plant Operation" for valves MO-2052A, MO-8811_, MO-2052B, and MO-8811B.
k k
LCA 26, Rsvicien 2 Page 5 of 11 21.
Page 3/4 7-1:
Change Specification 4.7.1.1 to the following:
"4.7.1.1 Each main steam line code safety valve shall be demonstrated OPERABLE, with lift settings and orifice sizes as shown in Table 4.7-1, when tested pursuant to Specifica-tion 4.0.5."
22.
Page 3/4 7-4, Table 4.7-1:
This change request has been deleted.
Pages 3/4 7-5, 3/4 7-6, and 3/4 7-6a:
23.
a.
(1) Specification 4.7.1.2.1.a:
(a) Redesignate Items a.1 and a.2 as b and c, respectively.
(b) Delete Items a.3 and a.4.
(c) redesignate Item a.5 as a; add at the beginning of rew a:
"At least once per 31 days by...".
(2) Change the new 4.7.1.2.1.b to read as follows:
"b.
By verifying that the diesel-driven pump starts and develops a discharge pressure of >1580 psig at 1200 RPM engine speed on recirculation flow when tested pursuant to Specification 4.0.5.
(3) Change the new 4.7.1.2.1.c to read as follows:
"c.
By verifying that the steam turbine-driven pump starts and develops a discharge pressure of >1580 psig at 4560 RPM on recirculation flow (when tested pursuant to Specification 4.0.5) when the secondary steam pressure is >800 psig. Pump OPERA-BILITY may be determined at lower pressures in MODES 2 or 3 by verifying that the steam turbine-driven pump starts and develops a discharge pressure of >1470 psig on l
recirculation flow (when tested pursuant to Specification 4.0.5) when the secondary pressure is >275 psig; however, OPERABILITY at 4560 RPM shall be verified within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after secondary steam pressure is increased above 800 psig."
(4) Old Specification 4.7.1.2.1.b:
(a) Redesignate this specification as d.
(b) Delete Item 1 and renumber Items 2 and 3, accordingly.
t k
LCA 26, Ravicien 2 Page 6 of 11 (5) Add a new Subsection 4.7.1.2.1.e as follows:
"e.
By verifying that each power operated (excluding automatic) valve in the flow path is OPERABLE when tested pursuant to Specification 4.0.5."
(6) Delece Specification 4.7.1.2.2.a.3.
(7) Delete Page 3/4 7-6a since this statement refers to a one-time activity that has_already occurred.
b.
Page 3/4 7-11: Change Specification 4.7.1.6 to the following:
"4.7.1.6 Each main steam line isolation valve that is open shall be demonstrated OPERABLE by verifying full closure within 5 seconds when tested prusuant to Specification 4.0.5."
24.
Page 3/4 7-13:
Specification 4.7.3.1:
a.
Change Specification 4.7.3.1.a to the following:
"a.
At least once per 31 days, by verifying that each valve (manual, power operated or automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position."
b.
Add a new Subsection 4.7.3.1.b as follows:
"b.
By verifying that each component cooling water cump is OPERABLE when tested pursuant to Specification 4.0.5."
c.
Redesignate old Subsection 4.7.3.1.b as 4.7.3.1.c and change to the following:
"c.
At least once per 18 months during shut-down, by verifying that each automatic valve servicing safety-related equipment actuates to its correct position on a safety injection test signal."
d.
Add a new Subsection 4.7.3.1.d as follows:
77 "d.
By verifying that each power operated (excluding automatic) valve in the flow path is OPERABLE when tested pursuant to Specification 4.0.5."
25.
Page 3/4 7-14: Delete specifications, leave page blank, and add the phrase:
"This page lef t intentionally blank".
< s LCA 26, Rsvision 2 Page 7 of 11 26.
Page 3/4 7-15:
Specification 4.7.4.1:
a.
Change Specification 4.7.4.1.a and b to the following:
"a.
At least once per 31 days, by verifying that each valve (manual, power operated and automatic) servicing safety-related equipment that is not locked, sealed, or otherwise secured in position, is in its correct position.
b.
Add a new Subsection 4.7.4.1.b as follows:
"b.
By verifying that each Service Water and Service Water Booster Pump is OPERABLE when tested pursuant to Specification 4.0.5."
Redesignate old Subsection 4.7.4.1.b as 4.7.4.1.c and change c.
this specification to the following:
"c.
At least once per 18 months during shut-down, by verifying that each automatic valve servicing safety related equipment actuates to its correct position on a safety injection test signal."
d.
Add a new Subsection 4.7.4.1.d as follows:
"d.
By verifying that each power operated (excluding automatic) valve is OPERABLE when tested pursuant to Specification 4.0.5."
27.
Page 3/4 7-16:
Delete specifications, leave page blank, and add the phrase:
"This page left intentionally blank".
28.
Page 3/4 0-3 (Specification BASES 4.0.5):
Acted on in Amendment 61.
29.
Page B 3/4 4-la:
In Specification 3/4.4.2 and 3/4.4.3, delete the comma and words "..., 1974 Edition," in the last line of the last paragraph.
30.
Page B 3/4 4-2a:
Specification 3/4.4.5: Acted on in Amendment 61.
31.
Page B 3/4 4-9:
Specification 3/4.4.10: Acted on in Amendment 61.
32.
Page B 3/4 4-10:
Specification 3/4.4.10: Acted on in Amendment 61.
REASON FOR CRANGE License Change Request (LCR) TNP-76-23 was originally issued and submitted to the NRC (as LCA 26 on April 22, 1977) to update the ASME Code reference for inservice inspection (ISI) in the Trojan Technical Specifications (Appendix A to Facility Operating License NPF-1).
No attempt was made to
LCA 26, Revision 2 Page 8 of 11
]
incorporate the ASME Code requirements for inservice testing (IST) of pumps and valves in LCR TNP-76-23. _The Code of Federal Regulations, l
10 CFR 50.55a(g), required all nuclear plant licensees (holders of Construction Permits as well as Operating Licenses) to review and update-their ISI and IST programs every 40 months and 20 months, respectively.
},
Since the Trojan Facility Operating License was issued prior to March 1, 1976, the requirements for IST of pumps and valves did not become ef fec-tive until the start of the next regular 40-month period, which was Septenber 20, 1979.
Subsequently PCE has received additional guidance from the NRC in regard to the submittal of IST programs (A. Schwencer letter to C. Goodwin, Jr., of January 13, 1978) and a request from the NRC for additional information in regard to LCR TNP-76-23 (A. Schwencer to C. Goodwin, Jr.,
of March 16, 1978). Additionally, the NRC issued a revision to 10 CFR i
50.55a(g) providing more flexibility in the use and application of the various editions of and addenda to the Code, increasing the IST interval to that of ISIS, and increasing both to 120 months (10 years).
Therefore, LCR TNP-79-01 (Rev. 0) was prepared to revise LCR TNP-76-23 1
(LCA 26) and incorporate the more recent requirements and requests for information in accordance and compliance with 10 CFR 50.55a(g). LCR TNP-79-01 (Rev. 0) was reviewed and approved by the Plant Review Board (PRB) and Nuclear Operations Board (NOB) and submitted to the NRC as Rev. I to LCA 26.
Subsequently the NRC issued Amendment 61 to Facility Operating License 4
NPF-1 which included ISI-related Technical Specification changes and a requirement (in Technical Specification 4.0.5) to perform the inservice testing of pumps and valves. However, the remaining IST-related changes in LCR TNP-79-01 (Rev. 0) were not acted on by the NRC.'
The proposed Rev. I to LCR TNP-79-01 includes most of the IST-related changes in Rev. O L
and proposes additional changes to (1) clarify the relationship between the Technical Specifications and the IST program where flow paths and I
systems are required to be operable, (2) make the Technical Specification l
and IST program requirements more consistent with one another, (3) incor-l porate changes based on more recent requirements, and (4) incorporate changes based on experience gained during implementation of the IST program. These changes are described in more detail in the following paragraphs.
In order to differentiate between the new changes proposed I
under this Revision 1 to LCR TNP-79-01 and those changes that have already been reviewed and approved by the PRR and NOB in Rev. O to LCR TNP-79-01, the format used in Rev. O has been repeated here with Revi-sion 1 changes being noted by side bars.
1.
Item 1 regarding Technical Specification 4.0.5 has already been acted on by the NRC in Amendment 61 to the Trojan Nuclear Plant Technical Specifications.
2.
a.
The v. tious surveillance requirements in the Technical Speci-fications for Class 1, 2, and 3 pumps and valves need to be changed to reference ASME Section XI and 10 CFR 50.55a(g) l.
s LCA 26, Revision 2 Page 9 of 11 via Specification 4.0.5.
The safety-related values for determining operability are to remain in the Technical Specifications. Valve closing times for Containment isola-tion valves remain in the Technical Specifications. Pump discharge pressures and flows, where applicable, remain in the Technical Specifications.
b.
Revision 1 to LCR TNP-79-01 proposes additional references to 4.0.5 in Technical Specifications where systems and flow paths are required to be operable, and Revision 0 to LCR TNP-79-01 removed valve cycling and/or pump operability requirements.
This will help identify when a Technical Specification action statement needs to be followed in the event that a pump or valve is determined to be inoperable.
c.
Revision 1 to LCR TNP-79-01 also replaces certain surveillance requirements from the Technical Specifications for the boron injection flow path (Modes 1 through 4), auxiliary feedwater pumps, and main steam isolation valves with references to Specification 4.0.5 since these components are being tested per the IST program. This will eliminate the need to test these valves under two different sets of requirements.
d.
Technical Sepcification Table 3.6-1 was modified to state that valves MO-2052A&B and 8811A&B are testable during Plant opera-tion since these valves are being tested during operation under the IST program.
3.
In general, valve cycling to determine operability is incorporated in the IST program for valves and is no longer required to be in the Technical Specifications.
4.
Revision 1 to LCR TNP-79-01 deletes the proposed change to the setpoint tolerance (+) limits on the pressurizer and main steam line safety valves, since adequate justification for the change has not been presented.
SAFETY EVALUATION The changes proposed by this LCR have been reviewed and determined to not constitute an unreviewed safety question. No new accidents are created and the probability and consequences of accidents previously considered remain unchanged. No effects upon the environment will result from these changes in surveillance testing of ASME Class 1, 2 and 3 equipment and components.
The changes proposed by this LCR are compatible with Revision 4 to NUREG-0452 (Fall 1981).
NUREG-0452 is the NRC publication of Standard Technical Specifications for Westinghouse PWRs. As such, NUREG-0452 has been reviewed and determined to not constitute an unreviewed safety question by the NRC.
The changes in the surveillance requirements of ASME Class 1, 2, and 3 equipment and components in the Trojan Technical L
LCA 26, Revision 2 Page 10 of 11 Specifications are due to NUREC-0452, 10 CFR 50.55a(g), and Section XI of the ASME Boiler and Pressure Vessel (BPV) Code.
Although some of the changes made to include additional references to Technical Specification 4.0.5 (such as those given in Technical Specifica-tion 4.7.1.2.1 for the auxiliary feedwater pumps) are above and beyond those given in NUREG-0452, they will not decrease the Plant safety margin since surveillance testing on a practical frequency pursuant to Specifica-tion 4.0.5 will be performed to provide assurance that the components involved will be operable when required. Testing frequencies pursuant to Specification 4.0.5 will be in accordance with an ASME Section XI addenda that has been approved by the NRC under 10 CFR 50.55a, except where specific relief has been granted by the NRC.
Valse closure times for valves MO-2052A and B, MO-2069A and B, and MO-8811A and B were not included in Table 3.6-1 since these times are being deleted under LCR TNP 82-01 (LCA 84). Revision 1 to LCR TNP 79-01 includes addi-tional changes to Table 3.6-1 in that valves MO-2052A and B and MO-8811A and B are being reclassified as being testable during operation. This is being done at the request of the NRC to be consistent with IST program requirements. MO-2052A and B and MO-8811A and B are Contaiment isolation valves on the SIS recirculation sump lines outside Containment and are not automatically operated.
They are normally closed with control power deenergized (as required by Technical Specification 4.5.2.a for M0-8811A and B) and do not receive a Containment isolation signal or safety injec-tion signal. Therefore, should one of the valves fail open during test-ing, MO-2069A and B would have to be energized and closed inside Contain-ment to provide Containment isolation. The redundant train would be available for ECCS operation during accident situations.
Safety-related acceptance criteria for certain pumps and valves are retained in the surveillance requirement Technical Specifications.
Certain pump discharge pressures and flows that are necessary to mitigate the consequences of an accident remain in the Technical Specifications, although the testing of those pumps will now be performed in accordance with Section XI of the ASME BPV Code. Likewise, certain valve closing times such as for Containment isolation valves and the main steam isolation valves remain in the Technical Specifications, whereas most valve cycling for operability has been transferred to the IST program. The removal of the specific requirements to cycle certain safety-related valves to determine operability from the Technical Specifications and insertion in l
the IST program does not indicate a decrease in or degradation of Plant safety; the testing requirements of the IST program are more extensive than those required by the Technical Specifications. The requirement to start a pump from the control room as a part of the operability test is deleted since no safety-related pumps depend upon a manual start from the control room to accomplish their design functions. Furthermore, the control circuitry for pump starts can be verified by other means than actually starting a pump.
l
LCA 26, Revicion 2 Page 11 of 11 In general, the testing requirements of pumps and valves are changed in a manner that is likely to improve equipment performance and reliability by more stringent testing criteria and by testing on a more practical frequency.
It is felt that the Plant safety margin would be increased vice decreased by this LCR.
BASIS _FOR DETERMINATION OF AMENDMENT CLASS This determination is not applicable because this LCR will result in a revision to LCA 26, which was submitted to the NRC prior to the effective date of 10 CFR 170. As such, no fee is required.