ML20059H954

Proposed Tech Specs Revising Surveillance Frequency & Acceptance Criteria

ML20059H954
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	11/04/1993
From:	COMMONWEALTH EDISON CO.
To:
Shared Package
ML20059H949	List: ML20059H945 ML20059H954
References
NUDOCS 9311100280
Download: ML20059H954 (11)

Text

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ATTACHMENT B PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF FACILITY OPERATION LICENSES I

DPR-39 AND DPR-48 REVISION OF THE MAIN STEAM SAFETY VALVE SURVEILLANCE REQUIREMENTS PAGES MODIFIED 156 160 163 PAGES ADDED None PAGES DELETED None r

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LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.7 STEAM GENERATOR EMERGENCY HEAT REMOVAL 4.7 STEAM GENERATOR EMERGENCY HEAT REMOVAL Aeolicability:

Acolicability:

Applies to auxiliary feedwater pump system, Applies to surveillance of auxiliary auxiliary feedwater supply system, and steam feedwater pump system, auxiliary feedwater generator safety valves supply system and steam generator safety valves.

Obiective:

Obiective:

To insure availability of the above system To insure adequate-plant cooldown capabili-and valves.

ties upon loss of normal feedwater flow and loss of main condenser vacuum.

Specification:

Specification:

1.

Steam Line Safety Valves 3.7.1 Steam LIne Safety Valves per unit per unit

% steam generator safety valves A.

A.

Twenty ASME code safety valves per Snit shall be tested for s (5 per-steam generator) shall be press e at each refueling OPERABLE whenever the reactor is outage.

esting shall be one by heated above 350"F except as a calibrat

~ auxiliary fting specified in 3.7.1.C, 3.7.1.D, device or by ench ta ing on and 3.7.1'.E.

compressed gas.

A east two of the valves teste hall be from each orifice e' e (

" or "R").

All valves a' unit 11 have

r. css ET' been tes at the end o each second efueling outage, e

g valv and the corresponding et p

sures and orifice sizes are dentified in Table 4.7-1.

B.

Deleted B.

Deleted i

156 Amendment Nos. 80 and 70 m

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8 (13 %)

Steam Generator Safety Valves Set Orifice-

' Steam. Flow,

Pressure Size-(LB/hr)

JA (2A)

E (2C)

E (2D)-

J,,H (2 B)

MS0014

-MS0019 MS0024 MS0029 1050 psig Q

584,105 MS0015 MS0020 MS0025 MS0030 1063 psig Q

.584,105.

MS0016 MS0021 MS0026

.MS0031 1076 psig R

845,763 MS0017 MS0022 MS0027 MS0032 1088 psig R

845,763 MS0018 MS0023 MS0028 MS0033 1100 psig R

845,763 Steam Generator Safety Valves, Set Pressures, Orifice Sizes, and Steam Flows TABLE 4.7-l' 160 Amendment Nos. 17 and 14

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' Bases:

417 h ting of at~1 east two safety valves o _

orifice size ass hat a

I *430 " 2 a representative le o ves.is m

tested at each refu The testing interval assu e avalla of the safety es.and of the-auxiliary _ water system.

The four hour delay in the surveillance and testing-cf the turbine driven auxiliary feed-water pump until'the reactor has reached the hot standby condition is to-prevent unnecessary cooldown of the reactor coolant system during periods when the reactor is not available as a heat source.

163 Amendment Nos. 80 and 70

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INSERTS 1.

The Steam Generator Safety Valve set p'ressures, specified in Table 4.7-1, sha'il be verified pursuant to Specification 4.0.5. Following testing, the set pressure of the valves tested shall be left within 11% of the values specified in Table 4.7-1.

i 2.

The testing of the Steam Generator Safety Valves and Auxiliary Feedwater Pumps -

pursuant to Specification 4.0.5 ensures equipment availability by testing in accordance

- with the ASME Inservice Testing Plan. The ASME Code establishes hdustry standard methods,' intervals, and record requirements for testing, as well as gaidelines for the' l

evaluation of test results. Although Table 4.7-1 allows a 3% set pressure toleranca for the OPERABILITY of the Steam Generator Safety Valves, each valve tested is reset to r

11% during surveillance testing to allow for setpoint drift.

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ATTACHMENT C SIGNIFICANT HAZARDS CONSIDERATION FOR PROPOSED CHANGES TO APPENDIX A

.-TECHNICAL SPECIFICATIONS OF FACluTY OPERATING UCENSES DPR-39 AND DPR-48 REVISION OF THE MAIN STEAM SAFETY VALVE SURVEILLANCE REQUIREMENTS F

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SIGNIFICANT HAZARDS CONSIDERATION FOR PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES 1

DPR-39 AND DPR-48 Commonwealth Edison has evaluated this proposed license amendment and determined that it involves no significant hazards considerations. According to 10CFR50.92(c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:

l 1.

Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated; I

2.

Create the possibility of a new or different kind of accident from any previously analyzed; or, 3.

Involve a significant reduction in a margin of safety. The following evaluation is provided for the three categories of the significant hazards consideration standards-l Commonwealth Edison proposes to revise the surveillance test requirements of Technical Specification 4.7.1.A pertaining to the Main Steam Safety Valves (MSSVs). The proposed change involves the incorporation of the ASME Section XI Inservice Testing (IST) Plan requirements into i

the Technical Specification applicabic to the MSSVs. The primary purpose of the MSSVs is to provide overpressure protection for the secondary system. The MSSVs also provide protection against overpressurizing the Reactor Coolant System by providing a heat sink for the removal of energy if the preferred heat sink, provided by the condenser and Circulating Water System, is not available. In order for the MSSVs to provide the required overpressure protection, the valves must open within the setpoint tolerances, relieve steam generator pressure and reseat when pressure is reduced. The operability of the MSSVs is determined by periodic surveillance testing l

in accordance with the Technical Specifications.

The following evaluation is provided for the three categories of the significant hazards consideration standards:

1.

Does the change involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated?

l The probability of an accider:t previously evaluated has not been increased. The l

proposed change does not change the fundamental function or capability of the MSSVs as described in the UFSAR. This change does not affect any initiators or precursors of an accident previously evaluated. This change will notincrease the likelihood that a transient initiating event will occur because most transients are initiated by equipment malfunction and/or catastrophic system failure. Since the proposed change does not involve the introduction of new or redesigned plant equipment, these failure mechanisms are not impacted.

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i SIGNIFICANT HAZARDS CONSIDERATION (continued)

The consequences of accidents previously evaluated are not increased.

The proposed t

change does not involve any equipment modifications which could adversely affect the l

expected accident sequence. Although the frequency of the MSSV surveillance testing is affected by the change, the frequency at which MSSV surveillances are performed is

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not assumed in any analyzed event. The changes in testing frenuency are consistent with the ASME/ ANSI Standard. The ASME/ ANSI Standard has been applied extensively l

throughout the industry and demonstrated adequate by the resulting industry experience.

l Therefore, accident analyses assumptions reflected in the affected Surveillance Requirements will still be verified on a frequency sufficient to ensure that the assumptions are reliably maintained.

l The role of these valves is in the mitigation of design basis accidents and transients. The effect of allowing the Z. ion station MSSV lift setpoint tolerance to increase from the currently required 11% to the 3% consistent with the ASME/ ANSI Standard has been evaluated for all non-LOCA and LOCA design basis requirements. The 13% tolerance for the MSSV setpoints was assumed in the VANTAGE 5 Reload Transition Safety Report for the Zion Units 1 and 2. In all cases, either a reanalysis incorporating the increased MSSV setpoint tolerance continued to show results within acceptance limits, or the MSSV -

setpoints were determined not to affect the licensing basis results. Even though the 13%

tolerance has been shown to be acceptable, the proposed change conservatively requires the MSSV setpoints to be restored to within 1% of the required value after testing. The remaining acceptance criteria of the IST program are at least as restrictive as existing Technical Specification requirements and ensure that an equivalent or greater degree of MSSV operational readiness is provided.

s Additionally, the relocation of Surveillance details to the IST program and its implementing procedures will not increase the probability or consequences of a previously evaluated accident since adequate control of the requirements is provided by the 10CFR 50.59' review process and ASME Section XI requirements incorporated by 10CFR 50.55a(g).

Therefore, this change does not involve a significant increase in the probability or i

consequences of an accident previously evaluated.

2.

Does the change create the possibility of a new or different kind of accident from any j

previously analyzed?

l The proposed change does not alter the design of the MSSVs or their function to protect against overpressure events. The proposed change does not introduce any new i

equipment, equipment modifications, or any new or different modes of plant operation.

Therefore, the proposed change does not introduce any new failure modes and the plant-will continue to be operated within acceptable limits. In addition, the proposed change still y

provides adequate assurance the MSSVs will be maintained operable.'

For the reasons described above, there is no possibility that the proposed change creates a new or different kind of accident from any previously analyzed in the UFSAR.

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1 SIGNIFICANT HAZARDS CONSIDERATION l

(continued) l 3.

Does the change involve a significant reduction in a margin of safety?

The proposed change incorporates the industry standard testing requirements of Section l

XI of the ASME Code and applicable Addenda for the MSSVs. The Zion IST program requirements and implementing procedures have been developed in accordance with the '

ASME Section XI requirements to ensure component degradation is detected before the component is incapable of performing its intended safety function.

Although the frequency of the MSSV surveillance testing is affected by the change, the frequency at which MSSV surveillances are performed is not assumed in any analyzed

-l event. The changes in testing frequency are consistent with the ASME/ ANSI Standard.

The ASME/ ANSI Standard has been applied extensively throughout the industry and demonstrated adequate by the resulting industry experience. Any reduction in a margin of safety is insignificant since the extension of the surveillance intervals is justified based on accepted industry practice and compliance with ASME Section XI as mandated by.

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10CFR50.55(a)g In addition, the proposed change has the potential to reduce testing that is typically done at power. Therefore, the proposed change reduces the risk of an i

unexpected plant transient that may be caused by online testing of the MSSVs.

The effect of allowing the Zion station MSSV lift setpoint tolerance to increase from the currently required 11% to the 3% consistent with the ASME/ ANSI Standard has been l

evaluated for all non-LOCA and LOCA design basis requirements. The 3% tolerance for the MSSV setpoints was assumed in the VANTAGE 5 Reload Transition Safetv Report for the Zion Units 1 and 2. In all cases, either a reanalysis incorporating the increased MSSV setpoint tolerance continued to show results within the acceptance limits, or the MSSV i

setpoints were determined not to affect the licensing basis results. Although the 3%

t tolerance has been shown to be acceptable, the proposed change conservatively requires the MSSV setpoints to be restored to within 1% of the required value after testing.

Therefore, modifying the applicable Technical Specification Surveillance Requirements for the MSSVs in accordance with the industry standards will not involve a significant i

reduction in the margin of safety.

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1 ATTACHMENT D l

t ENVIRONMENTAL ASSESSMENT FOR PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF

-j FACILITY OPERATING LICENSES DPR-39 AND DPR-48.

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REVISION OF THE MAIN STEAM SAFETY VALVE j

' SURVEILLANCE REQUIREMENTS l

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ENVIRONMENTAL ASSESSMENT FOR i

PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF i

FACILITY OPERATING LICENSES DPR-39 AND DPR-48.

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The changes proposed by this License Amendment Request have been evaluated against the l

criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10CFR51.21. It has been determined that the proposed changes meet the criteria for categorical exclusion as provided for under 10CFR51.22(c)(9). The following is a discussion of how the proposed changes meet the criteria for categorical exclusion.

l 10 CFR 51.22(c)(9):

i Although the proposed change involves changes to Surveillance Requirements:

i (i)

The proposed change involves no significant hazards consideration as evaluated in Attachment B of this License Amendment Request; (ii)

There is no significant change in the types, or significant increase in the amount, of any effluents that may be released offsite; and, (iii)

There is no significant increase in individual or cumulative occupational radiation exposure f

associated with this proposed change.

v Accordingly, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9). Based on the aforementioned and pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection i

with the issuance of this amendment to the licenses inceporating the proposed changes.

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