ML20125D199

Proposed Changes to Tech Spec Section 3.9,increasing Surveillance Requirements for Auxiliary Feedwater Pumps

ML20125D199
Person / Time
Site:	Fort Calhoun
Issue date:	06/10/1985
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20125D157	List: ML20125D154 ML20125D172 ML20125D199
References
NUDOCS 8506120276
Download: ML20125D199 (3)

Text

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3.0 SURVEILLANCE REQUIREMENTS 3.9 Auxiliary Feedwater System Applicability Applies to periodic testing requirements of the turbine-driven and motor-driven auxiliary feedwater pumps.

Objective To verify the operability of the auxiliary feedwater (AFW) system and its ability to respond properly when required.

Specifications (1) -The position of valves necessary to ensure auxiliary feedwater flow to the steam generators shall be veri-fied by a monthly inspection. Anytime maintenance is performed on the auxiliary feedwater system which alters valve alignments, an operator shall check that the AFW system valves are properly aligned, to ensure AFW flow to the steam generators, and a second operator shall independently verify proper valve alignment.

(2) The operability of the motor-driven auxiliary feedwater pump and the steam turbine-driven auxiliary feedwater pump shall be confirmed at least monthly.

(3) The operability of auxiliary feedwater pumps' steam gen-erator-level regulating valves HCV-1107A, HCV-1107B, HCV-1108A, HCV-1108B, and auxiliary feedwater cross-tie valve HCV-1384 shall be confirmed at least every three months.

(4) The capabilities of the motor-driven and turbine-driven auxiliary feedwater pumps shall be verified by using local pressure indicators and flow indicators in the control room. The discharge pressure will be verified

. to be 40 psig above the steam generator pressure at I

rated steam flow.

(5) Following cold shutdown and prior to raising the reactor i coolant temperature above 300 F, the motor-driven auxi-l liary feedwater pump shall be tested to verify the nor-mal 110w path for auxiliary feedwater to the steam gener-ators.

(6) At least once per 18 months during shutdown by:

i a. Verifying that each automatic valve in the flow path actuates to its correct position upon receipt of each auxiliary feedwater actuation test signal.

b. Verifying that each auxiliary feedwater pump starts as designed automatically upon receipt of each auxi-liary feedwater actuation test signal.

! Amendment No. O , 54 3-62 ATTACHMENT A L_b

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3.0 SURVEILLANCE REQUIREMENTS 3.9 Auxiliary Feedwater System (Continued)

Basis The valve position verifications performed monthly and fol-lowing. auxiliary feedwater system maintenance will confirm the availability of an auxiliary feedwater flow path to the steam generators.

The testing of the auxiliary feedwater pumps every month and after cold shutdowns will verify their operability by recir-culating water to the emergency feedvater storage tank.

Operating the regulating valves (HCV-1107A, HCV-1107B, HCV-1108A and HCV-1108B) one at a time every three months and after cold shutdowns will confirm a flow path to the steam generators and operability of the valves.

Proper functioning of the steam turbine admission valve and starting of the feedwater pump will demonstrate the integrity of the steam driven pump. Verification of correct operation will be made both from instrumentation within the main con-trol room and direct visual observation of the pumps.

The operability of the auxiliary feedwater system ensures that the reactor coolant system can be cooled down to less .

than 3500 F from normal operating conditions in the event of a total loss of off-site power.

References (1) USAR, Section 9.4 (2) Technical Specification 2.5 i.

Amendment'No. O , 54 3-62a

Discussion, Justification and Significant Hazards Considerations Discussion Technical Specification 3.9(2) is being changed to require monthly (every 31 days) operability testing of the Auxiliary Feedwater Pumps. In addition, the operability testing of the steam generator level regulating valves HCV-1107A and B, HCV-1108A and B and the cross-tie valve HCV-1384 has been separated from Specification 3.9(2) and re-numbered 3.9(3). The other specifications of Section 3.9 have been renumbered accordingly. The basis for Specifications in Section 3.9 has been changed to reflect the change in test frequency.

The proposed specification will reflect the testing requirements contained in the standard Technical Specifications for CE PWRs (NUREG-0212). Additionally, the increased operability test frequency will increase the reliability of the auxiliary feedwater pumps because the opportunity for discovery of equipment malfunction is increased by the more frequent running of the pumps.

Justification This change to the Technical Specifications is proposed at the request of the NRC. This change will place the Fort Calhoun Station Technical Specifications in conformance with the Standard Technical Specifications for CE PWRs (NUREG-0212) surveillance tesing frequency for Auxiliery Feedwater Pumps.

Significant Hazards Considerations The proposed change to Specification 3.9(2) has been reviewed relative to the provisions of 10 CFR 50.59 and resulted in the following conclusions:

The change will not involve a significant increase in the probability or consequences of an accident previously evaluated because only the surveillance interval for the pumps is being changed (reduced). This reduction in the surveillance interval will carry with it a commensur-ate increase in the reliability of the subject pumps.

The change will not create the possibility of a new or different kind of accident from any previously evaluated because only the surveillance interval is being changed. There are no changes in equipment or sur-veillance methodology.

The change will not involve a significant reduction in a margin of safety because the frequency of operability testing is being increased from a minimum of four (4) times per annum to a minimum of twelve (12) times per annum. The margin of safety will actually be increased be-cause more frequent operation of the pumps will increase pump and sys-tem reliability.

ATTACHMENT B

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