ML20059C519
| ML20059C519 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 10/28/1993 |
| From: | Drawbridge B NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | |
| Shared Package | |
| ML20059C518 | List: |
| References | |
| GL-93-05, GL-93-5, NUDOCS 9311010182 | |
| Download: ML20059C519 (7) | |
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geaggooxgranouum7, BahiinAtlantic Energy Service Corporation Facility Operating License NPF-86 Docket No. 50-443 License Amendment Request No. 93-14 Line item Technical Specification improvements to Reduce Testing During Power Operation This License Amendment Request is submitted by North Atlantic Energy Service Corporation pursuant to 10CFR50.90. The following information is enclosed in support of this License Amendment Request:
Section I Introduction and Description of Proposed Changes Section 11 Markup of Proposed Changes Section ill Retype of Proposed ChangesSection IV Safety Evaluation of Proposed ChangesSection V Determination of Significant Hazards for Proposed ChangesSection VI Proposed Schedule for License Amendment issuance and Effectiveness Section Vil EnvironmentalImpact Assessment Sworn and Subscribed to before me this J9 day of Od AA,1993 N*Y spy l d4
~6 e k 8 S d2ct m y Bruce L. Drawbrjdde N6fary Public Executive Director, Nuclear Production 9311010182 931028 O
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1.
Introduction and Description of Proposed Chances A.
Introduction The NRC issued NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements", in December 1992 to provide the results of a comprehensive examination of surveillance 6esting required by Technical Specifications. This document found that while some testing at power is essential to verify equipment and system operability, safety can be improved, equipment degradation decreased, and unnecessary personnel burden relaxed by reducing the amount of testing at power.
On September 27,1993 the NRC issued Generic Letter 93-05, "Line-Item Technical Specification improvements to Reduce Surs eillance Requirements for Testing During Power Operation" Using this Generic Letter, licensees are encouraged to propose Technical Specification changes that are consistent with the guidance provided.
B.
Statement of Compatibility with Operating Experience Of the forty-seven line items included in Generic Letter 93-05, North Atlantic has detennined that there are twelve Technical Specification changes where the recommendations of NUREG-1366 are completely compatible with plant operating experience. These changes are provided as items D.1 through D.12 below. One additional change is partially compatible with NUREG-1366. This change is pnLided as item D.13 below. During the review for item D.13, North Atlantic determined that implementing the recommendation of NUREG-1366 regarding certain conditions for loading the OPERABLE emergency diesel generator (EDG) to the grid could subject the EDG under test to grid faults which could adversely affect its ability to perform its safety function.
Therefore, North Atlantic has detennined that this recommendation is not compatible with plant operating experience.
As stated above, all other proposed changes are completely compatible with NUREG-1366 recommendations and are consistent with the guidance of Generic Letter 93-05.
C.
Determination of Costs Associated with the Proposed Technical Specification Changes The following information is submitted as requested in Generic Letter 93-05 to help the NRC in i
evaluating the cost of complying with the suggestion to propose Technical Specification changes.
1.
Licensee Staff Time and Costs to Prepare the Amendment Request Approximately 240 stafT hours were required to prepare the amendment request.
i 2.
Estimate of the Long-Term Savings lt is estimated that the proposed changes will result in a direct savings of 421 stafT hours for test personnel annually. 'Ihis figure is based on surveillance testing history and includes only test personnel. The consideration of planning, operations and data entry 1
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d-l personnel time double the savings. Therefore, these proposed changes will sne between 800 and 900 staff hours each year.
D.
Description of Proposed Changes The proposed Technical Specification changes are identified below with the Generic Letter 93-05 line item title and paragraph number. This is done to provide an easy cross-reference between the Generic Letter and the Seabrook Station Technical Specifications.
1.
Control Rod hiovement Test (4.2). The proposed change to Technical Specification 3/4.1.3, hiovable Control Assemblies,(Page 3/41-16) is described below:
The change to Surveillance Requirement 4.1.3.1.2 revises the frequency for detennining the OPERABILITY of each rod not fully inserted in the core from once every 31 days to once every 92 days.
This change is requested because industry experience has shown the performance of this testing, which requires movement of the rod by at least 10 steps, has resulted in dropped rods which in some cases has caused reactor trips.
2.
Hydrogen hionitor Surveillance (5.4). The proposed change to Technical Specification 3/4.6.4, Combustible Gas Control, (Page 3/4 6-18) is described below:
This change to Surveillance Requirement 4.6.4.1 revises the frequency for perfonnance of an ANALOG CilANNEL OPERATIONAL TEST (ACOT) from once every 31 days to once every 92 days, and a CllANNEL CAllBRATION from once every 92 days on a STAGGERED TEST BASIS to once every refueling interval.
These changes are based on the number of staff hours expended in the perfonnance of these tests and the requirement to open containment isolation valves during the perfonnance of the quarterly CllANNEL CAllBRATION.
The monthly ACOT requires about four staff hours and checks only the electronics portion of the hydrogen monitor. The quarterly CllANNEL CALIBRATION requires about 32 staff hours and checks the calibration of the hydrogen monitor using two gas samples, one containing 1% hydrogen the second containing 4% hydrogen. During the quanerly CHANNE.L CAllBRATION, manual containment isolation valves must be opened. The Technical Specifications require these valves to be locked closed, and they are opened under administratise control as allowed by the Technical Specifications.
Seabrook Station records and the Nuclear Plant Reliability Data System (NPRDS) equipment failure database show that the hydrogen monitors are highly reliable and do not warrant the present level of surveillance testirg.
3.
Radiation hionitors (5.14). The proposed changes to Technical Specifications 3/4.3.2, Engineered Safety Features Actuation System Instrumentation,(Page 3/4 3-32) and 3/4.3.3, hionitoring Instrumentation, (Page 3/4 3-39) are described below:
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A The changes revise Table 4.3-2, / Functional Unit 3.c.4, and Table 4.3-3, Functional Units I through 6, to change the ACOT and DIGITAL CilANNEL OPERATIONAL TEST (DCOT) frequencies from monthly to quarterly.
Industry experience has demonstrated that the testing of radiation monitors produces a signi6 cant number of isolations of the control room, fuel handling building, auxiliary buildings, and various process lines. Additionally, this testing requires significant staff hours to implement. Frequent testing of the equipment may also degrade its performance.
The radiation monitors at Seabrook Station have had a minimal failure history. Therefore, it is appropriate to extend the surveillance test interval as proposed in the Generic Letter.
4.
Reactor Coolant System Isolation Valves (6.1). The proposed change to Technical Specihcation 3/4.4.6, Reactor Coolant System 1.cakage,(Page 3/4 4-23) is described below:
The change to Surveillance Requirement 4.4.6.2.2.b extends the amount of time the plant can be shut down before pressure isolation valve (PlV) testing will be required. Currently, if the plant is in COLD SIIUTDOWN (Mode 5) less than three days, the PlVs do not have to be tested. This change extends the COLD SilUTI)OWN time from three days to seven days.
The present surveillance requirement is burdensome and can result in occupational exposure. PlV testing requires individual valve leakage measurements be obtained from thirty-one check valves and four motor-operated valves. This short surveillance test interval places unnecessary restrictions on the recovery from short forced outages where equipment reliability does not show such testing is required.
5.
liigh Point Vent Surveillance Testing (6.3).
The proposed change to Technical Specification 3/4.4.11, Reactor Coolant System Vents, (Page 3/4 4-38) is described below:
The change revises Surveillance Requirement 4.4.11.1 by changing the frequency for operating the Reactor Coolant System (RCS) vent valves through one complete cycle of travel from once per 92 days to once per COLD SilUTDOWN, if not performed within the previous 92 days.
'lhis change is recommended because testing of the RCS vent valves at pressure has i
potential to cause a release of reactor coolant.
6.
Pressurizer IIeaters (6.6).
The proposed change to Technical Specification 3/4.4.3, Pressurizer, (Page 3/4 4-10) is described below:
The change revises Surveillance Requirement 4.4.3.2 by changing the frequency of the pressurizer heater capacity measurement surveillance from quarterly to each refueling interval.
This change is recommended because the pressurizer heaters are in constant use, both the proportional and to some extent the backup heaters. Therefore, operators uould be aware of problems that may arise with pressurizer heaters. The pressurizer heaters are reliable.
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l At Seabrook Station these heaters have been tested on twenty-one occasions since 1987 without any failures.
7.
Surveillance of Boron Concentration in the Accumulators (7.1). The proposed change to Technical Speci6 cation 3/4.5.1, Accumulators (Page 3/4 5-2) is described below:
This change removes the requirement to verify boron concentration of accumulator inventory after a volume increase of 1% or more under speciGed conditions.
The veri 0 cation is not required if makeup is from the Refueling Water Storage Tank (RWST) and the minimum concentration of boron in the RWST is greater than or equal to the minimum boron concentration in the accumulator and the-RWST has not been diluted since the last RWST sample was veriDed to be within specification. In addition, the present surveillance requirement is burdensome and can result in occupational exposure.
8.
Accumulator Water Level and Pressure Channel Surveillance Requirements (7.4). The proposed change to Technical Specification 3/4.5.1, Accumulators, (Pages 3/4 5-1 & 5-2) l is described below:
This change deletes the accumulator water level and pressure channel ACOT and CilANNEL CAllBRATION from the Technical Specifications and places them into a -
licensee-controlled program. These changes are consistent with industry recognition that 4
accumulator instrumentation operability is not directly related to the capability.of the accumulators to perform their safety function.
9.
Visual Inspection of the Containment Sump (7.5). 1he proposed change to Technicai Specification 3/4.5.2, ECCS Subsystem - Tavg Greater than or Equal to 350 F, (Page 3/4 5-5) is described below:
This change to Surveillance Requirements 4.5.2.C.1) and 4.5.2.C.2) clarifies when the containment sump visual inspection must be performed.
1 Currently, inspections must be performed at the completion of each contamment entry.
Therefore, multiple jobs in one day would require multiple inspections. The proposed change will require that this inspection be performed at least once daily if the containment i
has been entered that day and when the Dnal containment entry is made. This change will reduce the number of unnecessary inspections and also reduce personnel exposure.
i 10.
Containment Spray System (8.1). The proposed change to Technical Specification 3/4.6.2, Depressurization and Cooling Systems,(Page 3/4 6-14) is described below:
i This change to Surveillance Requirement 4.6.2.1.d revises the containment spray system nonle testing surveillance frequency from once every five years to once every ten years.'
This change is recommended because this testing gives no quantitative data on Howrates exiting the nonles. The test only verifies that the Cow path is unobstructed. Industry operational data supports the frequency extension.
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F 11.
Ilydrogen Recombiner (8.5). The proposed change to Technical Specification 3/4.6.4, Combustible Gas Control,(Page 3/4 6-19) is described below:
This change to Surveillance Requirement 4.6.4.2 revises the containment hydrogen recombiner testing surveillance frequency from every six months to every refueling interval.
This change is recommended because of the redundancy and the high reliability of this system. At.Seabrook Station, this surveillance has been performed eighteen times since i
1990. On only one occasion was a problem noted, which resulted in a circuit breaker tripping. The breaker was reset and ftmetioned properly without any funher actions. Since l
the hydrogen recombiners are manually started many hours after a Loss of Coolant' Accident (LOCA) occurs, the system would still have been able to operate if called upon.
12.
Auxiliary Feedwater Pump and System Testing (9.1). The proposed change to Technical l
Specification 3/4.7.1.2, Auxiliary Feedwater System, (Pages 3/47-3&7-4) is described below:
l This change to Surveillance Requirement 4.7.1.2.1 revises the testing frequency for the emergency feedwater pumps and the staitup feedwater pump from at least once every 31 days on a STAGGERED TEST llASIS to at least once every 92 days on a STAGGERED TEST 13 ASIS.
This change is recommended because the high reliability of thesc pumps indicates they do not require such frequent testing. Insen' ice testing (IST) records at Seabrook. Station from 1990 show that these pumps have never had a problem associated with pump performance that required any rework. Also, current monthly testing causes wear and premature failure of associated components such as pressure isolation valves and check valves. This wear does not prevent the system from performing its required function but does increase the amount of time the system is not available due to maintenance caused by unnecescary testing.
13.
Emergency Diesel Generator Surveillance Requirements (10.1). The proposed change to Technical Specification 3/4.8.1, A.C. Sources, (Pages 3/48-1&8-2) is described below:
This change to the ACTION statements ofTechnical Specification 3.8.1.1 revises the action requirements for starting a non-afTected emergency diesel generator when the limiting conditions for operation of the electrical distribution system are degraded.
Current ACTION statements require alternate testing of a non-aiTected emergency diesel generators. This testing is performed to enhance emergency diesel generator reliability.
Industry experience has shown that alternate testing has, in fact, reduced reliability because emergency diesel generator reliability decreases as the number of quick starts increases.
When emergency diesel generator reliability testing is required because of a potential common mode failure, this change will require starting the emergency diesel generator.
NUREG-1366 recommends both starting and loading the emergency diesel generator under this condition. Under the Limiting Condition of Operation (LCO), with one emergency diesel generator inoperable and the operable emergency diesel generator requiring testing, 5
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. i the operable diesel should not be loaded. Loading the operable emergency diesel generator could subject it to grid faults which could adversely affect emergency diesel generator operation and could, in a worst case situation, result in a complete loss of all AC power (both offsite and onsite). This adverse condition was recognized by the NRC in a recent Notice of Violation to another licensee that cited the licensee for failing "...to avoid the potential for rendering all emergency diesel generators (EDG) unavailable by paralleling one or more EDGs to the grid while the remaining EDG(s) were inoperable.. " In this case the licensee's procedures required parallelling the operable EDG to the ofTsite power grid w benever the remaining EDG is inoperable. Therefore, the NUREG-1366 recommendation-to load the' emergency diesel generator in response to an action condition is not incorporated.
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