ML20076F468

Proposed Tech Specs Re Safety/Relief Valve Testing Requirements

ML20076F468
Person / Time
Site:	FitzPatrick
Issue date:	10/07/1994
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20076F460	List: JPN-94-051, Forwards Application for Amend to License DPR-59,changing TS Re Safety/Relief Valve Testing Requirements ML20076F463 ML20076F468
References
NUDOCS 9410170190
Download: ML20076F468 (15)

Text

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ATTACHMENT I TO JPN-94-051 PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING SRV TESTING REQUIREMENTS l (JPTS-94-004)

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 9410170190 941007 PDR ADOCK 05000333 P PDR

JAFNPP .-

3.6 (cont'd) 4.6 (cont'd)

E. Safety / Relief Valves E. Safetv/ Relief Valves

1. During reactor power operating conditions and prior to startup 1. At least 5 of the 11 safety / relief valves shall be bench from a cold condition, or whenever reactor coolant pressure checked or replaced with bench checked valves once is greater than atmosphere and temperature greater than each operating cycle. All valves shall be tested every 212 "F, the safety mode of at least 9 of 11 safety / relief va!ves two operating cycles.* The testing shall demonstrate sha!! be operable. The Automatic Depressurization System that each valve tested actuates at 1110 psig 3%.

valves shall be operable as required by specification 3.5.D. Following testing, lift settings shall be 1110 psig 11 %

• The current surveillance interval for bench checking safety / relief valves is extended until the end of R11/C12 refueling outage scheduled for January,1995. This is a one-time extension, effective only for this surveillance interval. The next surveillance interval will begin after the ccmpletion of the bench check testing and after the safety / relief valves are declared operable.

Amendment No. 40, EB,56,7'O,400,404,405, EW, 142a

JAFNPP -

3.6 (cont'd) 4.6 (cont'd)

2. If Specification 3.6.E.1 is not met, the reactor shall be placed in 2. At least one safetyirelief valve shall be disassembled and a cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. inspected once/ operating cycle.*

3. Low power physics testing and reactor operator training shall 3. The integrity of the nitrogen system and components which be permitted with inoperable components as specified in provide manual and ADS actuation of the safety / relief valves Specification 3.6.E.1 above, provided that reactor coolant shall be demonstrated at least or.co every 3 months.

temperature is s212 'F and the reactor vessel is vented or the reactor vessel head is removed.

4. The provisions of Specification 3.0.D are not applicable. 4. Manually open each safety / relief valve while bypassing steam to the condenser and observe a 210% closure of the turbine bypass valves, to verify that the safety / relief valve has opened.

This test shall be performed at least once each operating cycle while in the RUN mode and within the first 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after steam pressure and flow are adequate to perform the test.

5. The safety and safety / relief valves are not required to be operable during hydrostatic pressure and leakage testing with reactor coolant temperatures between 212 "F and 300 "F and irradiated fuel in the reactor vessel provided all control rods are inserted.

The current surveillance interval for disassembling and inspecting at least one safety / relief valve is extended until the end of R11/C12 refueling outage scheduled for January,1995. This is a one-time extension, effective only for this surveillance interval. The next surveillance interval will begin upon completion of this surveillance.

Amendment No. 43, M,460,404,479,495,247, 143

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JAFNPP -

3.6 and 4.6 BASES (cont'd)

E. Safetv/ Relief Valves The safety / relief valves (SRVs) have two modes of operation; with the HPCI and RCIC turbine overspeed systems and the the safety mode or the relief mode. In the safety mode (or Mark I torus loading analyses. Based on safety / relief valve spring mode of operation) the spring loaded pilot valve opens testing experience and the analysis referenced above, the when the steam pressure at the valve inlet overcomes the spring safety / relief valves are bench tested to demonstrate that force holding the pilot valve closed. The safety mode of in-service opening pressures are within the nominal pressure operation is required during pressurization transients to ensure setpoints 3% and then the valves are returned to service with vessel pressures do not exceed the reactor coolant pressure opening pressures at the nominal setpoints 1% in this manner, safety limit of 1,375 psig. valve integrity is maintained from cycle to cycle.

In the relief mode the spring loaded pilot valve opens when the The analyses with NEDC-31697P also provide the safety basis spring force is overcome by nitrogen pressure which is provided for which 2 SRVs are permitted inoperable during continuous to the valve through a solenoid operated valve. The solenoid power operation. With more than 2 SRVs inoperable, the margin operated valve is actuated by the ADS logic system (for those to the reactor vessel pressure safety limit is significantly reduced, SRVs which are included in the ADS) or manually by the therefore, the plant must enter a cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operator from a control switch in the main control room or at the once more than 2 SRVs are determined to be inoperable. (See remote ADS panel. Operation of the SRVs in the relief mode for reload evaluation for the current cycle).

the ADS is discussed in the Bases for Specification 3.5.D.

A manual actuation of each SRV is performed to demonstrate l Experiences in safety / relief valve testing have shown that failure that the valves are mechanically functional and that no blockage or deterioration of safety / relief valves can be adequately detected exists in the valve discharge line. Valve opening is confirmed by if at least 5 of the 11 valves are bench tested once per operating monitoring the response of the turbine bypass valves and the cycle so that all valves are tested every two operating cycles. SRV acoustic monitors. Adequate reactor steam dome pressure Furthermore, safety / relief valve testing experience has must be available to avoid damaging the valve. Adequate steam demonstrated that safety / relief valves which actuate within 3% fitw is required to ensure that reactor pressure can be of the design pressure setpoint are considered operable (see maintained during the test. Testing is performed in the RUN ANSI /ASME OM-1-1981). The safety bases for a single nominal mode to reduce the risk of a reactor scram in response to small valve opening pressure of 1110 psig are described in pressure flucuations which may occur while opening and NEDC-31697P, " Updated SRV Performance Requirements for reciosing the valves.

the JAFNPP." The single nominal setpoint is set below the reactor vessel design pressure (1250 psig) per the requirements Low power physics testing and reactor operator training with of Article 9 of the ASME Code - Section lit, Nuclear Vessels. inoperable components will be conducted only when the The setting of 1110 psig preserves the safety margins associated safety / relief valves are l

Amendment No. 43,404, BW, 152

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ATTACHMENT ll to JPN-94-051 l SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING SRV TESTING REQUIREMENTS (JPTS-94-004)

New York .'awer Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59

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Attachment 11 to JPN-94-051 SAFETY EVALUATION Page 1 of 5

1. DESCRIPTION OF PROPOSED CHANGES This application for an amendment to the James A. FitzPatrick Technical Specifications proposes to revise the surveillance requirement for Reactor Coolant System (RCS) safety /reli3f valve testing so that the time allowed for testing does not start before the  ;

conditions necessary for these tests exist.

Editorial char es to clarify the intent of specifications involving safety / relief valve - j testing and pe u. nance requirements are also proposed.

Minor changes in format, such as type font, margins or hyphenation, are not described in this submittal. These changes are typographicalin nature and do not affect the content of the Technical Specifications. l Plant Conditions for Safetv/ Relief Valve Testing I

1. Page 143, Specification 4.6.4, last sentence, replace the phrase:

" withir, the first 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of continuous power operation at a reactor steam dome pressure of 2940 psig."

with: s

" while in the RUN mode and within the first 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after steam pressure and flow are adequate to perform the test."

2. Page 152, Bases 3/4.6.E, fifth paragraph:

Replace the second and third sentences, beginning with " Adequate reactor steam dome pressure..." with the following:

" Valve opening is confirmed by monitoring the response of the turbine bypass valves and the SRV acoustic monitors. Adequate reactor steam dome pressure must be available to avoid damaging the valve. Adequate steam flow is required to ensure that reactor pressure can be maintained during the test.

Testing is performed in the RUN mode to reduce the risk of a reactor scram in response to small pressure fluctuations which may occur while opening and reclosing the valves."

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,. 4 Attachment 11 to JPN-94-051 SAFETY EVALUATION Page 2 of 5 Editorial Changes

1. Page 142a, Specification 4.6.E.1, replace the phrase:

" the 11 safety / relief valves actuate at 1110 psig13%."

with:

" .each valve tested actuates r.t 1110 psig

. 3%."

2. Page 142a, Specification 4.6.15.1, add new sentence:

"Following testing, lift settings shall be set at 1110 psig i 1%."

3. Page 152, fifth paragraph:

Replace the word " verify" in the first sentence with " demonstrate."

4. Page 152, last paragraph. Delete the words "and safety" from the phrase ". . safety / relief and safety valves..."

ll. PURPOSE OF THE PROPOSED CHANGES f

Plant Conditions for Safetv/ Relief Valve Testina A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit was recently'added (Reference 2) to Surveillance Requirement 4.6.4 to perform the manual testing of the RCS safety / relief valves. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit, included in the Standard Technical Specifications (Reference 3), establishes a reasonable time limit for plant operators to conduct valve testing. However, as presently worded, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time period begins before appropriate plant conditions have been established to perform the test.

One SRV has a steam flow capacity of approximately 700,000 lb/hr with the RCS pressure at 940 psig. This corresponds to a reactor power level of nearly 7%. ,

Conducting SRV testing before an appropriate steaming rate is established will result in a undesirable pressure transient in the RCS. The proposed changes will specify that steam flow, in addition to RCS pressure, is a prerequisite to conducting valve testing.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit will remain in effect , but will not begin until necessary test conditions are established. The revised specification is consistent with a recent amendment granted by the NRC for another facility (Reference 4).

Editorial Changes

1. Specification 4.6.E.1 describes the surveillance requirement for demonstrating the -

lift setpoint of the safety / relief valves. Approximately half of the 11 valves are tested each operating cycle. The present wording of the specification could be l

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Attachment 11 to JPN-94-051 SAFETY EVALUATION Page 3 of 5 misinterpreted to require that the lift setpoint be demonstrated for all 11 valves each operating cycle. The proposed changes make it clear that the lift setpoint can only be demonstrated for those valves that are tested that cycle.

2. The acceptance criterion for the as-foundsafety/ relief valve lift setpoint is different from that allowed for the as-installed setpoint. This difference is stated in the Bases Section,3/4.6.E (third paragraph). The changes proposed add a similar sentence to Surveillance Requirement 4.6.E.1.

3. Tho word ' verify', as used in the FitzPatrick Technical Specifications, ensures that the associated surveillance tests have been performed with satisfactory results in the specified time interval, while the word ' demonstrate' requires the performance of an actual test. This change was made in other sections of the Technical '

Specifications by Amendment 148 (Reference 5). The word ' demonstrate' is appropriate in this case, since Specification 4.6.E.4 requires actuation of the safety / relief valves.

4. The proposed change to the last paragraph of Bases Section 3/4.6.E eliminates l reference to valves which are no longer installed at FitzPatrick. Amendment 13 '

updated the Technical Specifications to reflect the replacement of two spring safety valves with Target Rock combination safety / relief valves (Reference 6).

111. SAFETY IMPLICATIONS OF THE PROPOSED CHANGES Plant Conditions for Safetv/ Relief Valve Testina  ;

The proposed changes do not adversely affect plant safety. The conditions uder  !

which valve safety / relief testing are performed are not being changed. The proposed changes allow the time limit specified to conduct valve testing to start after rs! ant conditions required to support valve testing have been established.

Prior to the issuance of Amendment 217 (Reference 2), the manual testing of the safety / relief valves was performed with no time limit specified. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time limit was added to improve consistency with the Standard Technical Specifications. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period is a somewhat arbitrary value, based en good judgement and experience, to provide a reasonable length of time for plant operators to perform the valve testing. j The purpose of Specification 4.6.E.4 is to demortstrate that the safety / relief valves are functional and that no blockage is present in the valve discharge piping. The testing is conducted during the early stages of power ascension, with reactor power level less i than 25% and at a steaming rate which can be accommodated by the turbine bypass )

valves. FitzPatrick has 11 safety / relief valves with a total discharge capability greater than 80% of the full power steaming rate. Each safety / relief valve has separate discharge piping to the torus so that no common mode failure exists with respect to a blockage of the discharge piping. In addition, at least 5 of the 11 safety / relief valves l

l Attachment 11 to JPN 94-051 SAFETY EVALUATION Page 4 of 5 are bench checked once each operating cycle (Specification 4.6.E.1). Bench checking is conducted with live steam and includes verifying, or resetting if needed, the lift setpoint. Consequently, there is a high degree of confidence, even before the manual valve testing is performed, that sufficient safety / relief valve capacity is available to provide Reactor Coolant System overpressure protection.

Editorial Changes These proposed changes are editorial in nature and clarify the intent of the existing T hnical Specifications. The changes have no safety implication.

IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the James A. FitzPatrick Nuclear Power Plant in accordance with the proposed amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92, since it would not:

1 involve a significant increase in the probability or consequences of an accident previously evaluated because the proposed changes do not change the test  ;

method or conditions under which valve testir g may be performed and there is no affect on assumptions used for previously analyzed accidents. The original operating license for FitzPatrick did not specify any time limit for completing manual testing of the safety / relief valves.

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2. create the possibility of a new or different kind of accident from those previously evaluated because the proposed amendment does not involve any modification of plant equipment or changes in plant operating conditions.

3. involve a significant reduction in the margin of safety because the proposed amendment makes no changes to the operability or performance requirements for the safety / relief valves incluc!ing the ADS function. Valve lift setpoints and the minimum number of operable valves required are not affected.

V. IMPLEMENTATION OF THE PROPOSED CHANGES Implementation of the proposed changes will be accomplished through changes to the plant procedures for testing the safety / relief valves. There are no physical plant modifications required. The proposed changes will not affect the ALARA, Fire Protection, or Security Programs at the FitzPatrick plant, nor will the changes impact the environment.

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Attachment ll to JPN-94-051 SAFETY EVALUATION Page 5 of 5 VI. CONCLUSION The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they:

1. will not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Safety Analysis Report;

2. will not increase the possibility of an accident or malfunction of a type different than any previously evaluated in the Safety Analysis Report; and

3. will not reduce the margin of safety as defined in the basis for any technical l specification.

i l The changes therefore involve no significant hazards consideration, as defined in 10 CFR 50.92.

Vll. REFERENCES

1. NYPA letter W. A. Jcsiger to NRC (JPN-94-013) dated March 2,1994; " Proposed Changes to the Technical Specifications Regarding Updated SRV Performance Requirements and Miscellaneous Changes (JPTS-89-017)."

2. NRC letter, J. E. Menning to W. J. Cahill, Jr.; regarding issuance of Amendment 217, dated September 28,1994.

3. NRC NUREG-1433, " Standard Technical Specifications for General Electric Boiling Water Reactors, (BWR / 4) Revision 0, dated September 1992.

4. NRC letter, D. Pickett to R. Phares; regarding issuance of Amendment 81 for

, Clinton Power Station, dated July 15,1993.

5. NRC letter, D. E. LaBarge to J. C. Brons; regarding issuance of Amendment 148, dated December 26,1989.

6. NRC letter, R. Reid to G. Berry; regarding issuance of Amendment 13, r dated March 5,1976.

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ATTACHMENT lll TO JPN-94-051 MARKED UP PAGES FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING SRV TESTING REQUIREMENTS l (JPTS-94-004)

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 l

, JAFNPP

3.6 (cont'd) 4.6 (cont'd)

Safetv/ Relief Valves E. E. Safetv/ Relief Valves

1. During reactor power operating conditions and prior to startup 1. At least 5 of the 11 safety / relief valves shall be bench from a cold condition, or whenever reactor coolant pressure checked or replaced with bench checked valves once '

is greater than atmosphere and temperature greater than each operating cycle. All valves shall be tested every two

212 *F, the safety mode of at least 9 of 11 safety / relief valves on shall be operable. The Automatic Depressurization System operating cycles.*

safctylrc'ici vaNc3 TheedelfvielWije actuate test _ing s_

ettacW"aiteshall dem_sl,s_tr_ at ate valves shall be operable as required by specification 3.5.D. 3% M'idiilig(M5Mjshs(tyfiiff4 i i I

• The current surveillance interval for bench checking safety /reliet valves is extended until the end of R11/C12 refueling outage scheduled for January,1995. This is a one-time extension, effective only for this surveillance interval. The next surveillance >

interval will begin after the completion of the bench check testing -

and after the safety / relief valves are declared operable.

Amendment No. 13,28,56.70,130,134,195,217 142a (markup)

JAFNPP --

3.6 - (cont'd) 4.6 (cont'd)

2. If Specification 3.6.E.1 is not met, the reactor shall be placed in 2. At least one safety / relief valve shall be disassembled an'd a cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. inspected once/ operating cycle.* *

3. Low power physics testing and reactor operator training shall 3. The integrity of the nitrogen system and components which be permitted with inoperable components as specified in provide manual and ADS actuation of the safety / relief valves Specification 3.6.E.1 above, provided that reactor coolant shall be demonstrated at least once every 3 months.

temperature is s212 'F and the reactor vessel is vented or the reactor vessel head is removed.

4. The provisions of Specification 3.0.D are not applicable. 4. Manually open each safety / relief valve while bypassing steam to the condenser and observe a 210% closure of the turbine -

bypass valves, to verity that the safety / relief valve has opened.

This test shall be performed at least once each operating cycle

,sithin the first 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of continuous pcwcr ^^cratica at a

5. The safety and safety / relief valves are not required to be operable during hydrostatic pressure and leakage testing with .;

reactor coolant temperatures between 212 F and 300 F and irradiated fuel in the reactor vessel provided all control rods are i inserted.

The current surveillance interval for disassembling and inspecting  !

I at least one safety / relief valve is extended until the end of R11/C12

! refueling outage scheduled for January,1995. This is a one-time . ,

l extension, effective only for this surveillance interval. The next  ;

surveillance interval will begin upon completion of this surveillance.-

Amendment No. 43,70,130,134,179,195,217  ;

l 143 (markup)  ;

'. ~..

JAFNPP

4 3.6 and 4.6 BASES (cont'd) .

E. Safetv/ Relief Valves The safetyirelief valves (SRVs) have two modes of operation; of Article 9 of the ASME Code - Section Ill, Nuclear Vessels.

the safety mode or the relief mode. In the safety mode (or The setting of 1110 psig preserves the safety margins associated spring mode of operation) the spring loaded pilot valve opens with the HPCI and RCIC turbine overspeed systems and the when the steam pressure at the valve inlet overcomes the spring Mark I torus loading analyses. Based on safety / relief valve force hniding the pilot valve closed. The safety mode of testing experience and the analysis referenced above, the operation is required during pressurization transients to ensure safety / relief valves are bench tested to demonstrate that vessel pressures do not exceed the reactor coolant pressure in-service opening pressures are within the nominal pressure safety limit of 1,375 psig. setpoints 3% and then the valves are returned to service with opening pressures at the nominal setpoints 1%. In this manner, in the relief mode the spring loaded pilot valve opens when the valve integrity is maintained from cycle to cycle, spring force is overcome by nitrogen pressure which is provided to the valve through a solenoid operated valve. The solenoid The analyses with NEDC-31697P also provide the safety basis operated valve is actuated by the ADS logic system (for those for which 2 SRVs are permitted inoperable during continuous SRVs which are included in the ADS) or manually by the power operation. With more than 2 SRVs inoperable, the margin operator from a control switch in the main control room or at the to the reactor vessel pressure safety limit is significantly reduced, remote ADS panel. Operation of the SRVs in the relief mode for therefore, the plant must enter a cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the ADS is discussed in the Bases for Specification 3.5.D. once more than 2 SRVs are determined to be inoperable. (See reload evaluation for the current cycle).

Experiences in safety! relief valve testing have shown that failure or deterioration of safety / relief valves can be adequately detected A manual actuation of each SRV is performed to venfy

, if at least 5 of the 11 valves are bench tested once per operating 3eWfdliff$ that the valves are mechanically functional and that cycle so that all valves are tested every two operating cycles. no blockage exists in the valve discharge line. Adequate reactor Furthermore, safety / relief valve testing experience has sicam dome pcc33urc must bc availcb!c to perform this tcat, in demonstrated that safety / relief valves which actuate within 3% accordance ;Mh the manufacturcr's recommendations, to avoid of the design pressure setpoint are considered operable (see damaging the valvc. Thereforc, plant sta'i up is cllcveed and ANSI /ASME OM-1-1981). The safety bases for a single nominal sufficient time is provided after the rc uired rc33urc is achieved valve opening pressure of 1110 psig are described in '040 poig) to perform this tcat. [MiiiNkM-NEDC-31697P, " Updated SRV Performance Requirements for the JAFNPP." The single nominal setpoint is set below the Low power physics testing and reactor operator training with reactor vessel design pressure (1250 psig) per the requirements inoperable components will be conductec anly when the safety / relief and safety valves are 1

Amendment No. 43,134,217 152 (markup)

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