ML20133B916

Forwards SER Addressing Licensing Action Re Low Temp Overpressure Protection Sys.Salp Input,Draft Ltr to Licensee,License Amend & Revised Tech Specs Also Encl.Tac 59325 Closed

ML20133B916
Person / Time
Site:	Rancho Seco
Issue date:	09/30/1985
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Thompson H Office of Nuclear Reactor Regulation
References
TAC-59325, NUDOCS 8510070157
Download: ML20133B916 (3)

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SEP 3 01985 HEMORANDUM FOR: Hugh L. Thompson,' Jr. , Director Division of Licensing, NRR .

FROM: Dennis F. Kirsch, Acting Director Division of Reactor Safety and Projects

SUBJECT:

REGION V SAFETY EVALUATION REPORT FOR RANCHO SECO NUCLEAR GENERATING STATION OVERPRESSURE PROTECTION TECHNICAL SPECIFICATI0hs TAC NO. 59325 Plant Name: Rancho Seco Docket Number: 50-312 Responsible Branch: Operating Reactors Branch No. 4 Project Manager: S. Miner Review Status: Complete Enclosed is the Region V Safety Evaluation Report addressing the subject licensing action. We have also enclosed a draft letter to the licens'ee, a draft license amendment, revised technical specification pages and page replacement instructions. Inasmuch as this action has been completed, TAC Number 59325 may be closed.

We have also enclosed the SALP input requested by NRR Office Letter Number 44.

If you have any questions regarding this SER, please contact Jerry Zwetzig at FTS 463-3749.

Origirid t![ned E/

R. J. Pah Dennis F. Kirsch, Acting Director Division of Reactor Safety and Projects

Enclosures:

As Stated cc w/ enclosures:

S. Miner, NRR J. Stolz, NRR J. Carter,'.NRR F. Miraglia, NRR J. Eckhardt, RV L. Miller, RV R. Pate, RV G. Zwetzig, RV Via 5520: Division of Licensing, NRR, Attn: S. Miner ID: Rancho TAC No. 59325 t

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I SALP INPUT FOR COMPLETED SER Organization Prepar ng SALP Input: Region V i Facility: Rancho Seco Docket No.: 50-312 Phase: Operating SER

Subject:

Overpressure Prot. Tech. Spec. TAC No. 59325 Functional Area: Licensing Activities Evaluation Criteria

1. Management Involvement in Assuring Quality l

The licensee's submittals reflected a management program where activities affecting quality were usually under control. It appemts decision-making generally occurred at an appropriate level.

Rating: Category 2

2. Approach to Resolution of Technical Issues from a Safety Standpcint The licensee's submittals reflected a good understanding of the technical and safety issues involved and provided a conservative approach to the problem.

Rating: Category 1

3. Responsiveness to NRC Initiatives The licensee was generally very responsive to the guidance contained in the staf f's earlier Safety Evaluation. The only exceptions to the guidance proposed by the licensee were prcapted by operational 1

necessities or a concern for avoiding equipment damage.

I Rating: Category 1

4. Reporting and Analysis of Reportable Events Not observed.

Rating: None

5. Staffing (Including Management)

Not observed.

Rating: None

6. Training and Qualification Effectiveness Not observed.

Rating: None 1

r D-R-A-F-T Docket No. 50-312 Mr. Ronald J. Rodriguez Executive Director, Nuclear Sacramento Municipal Utility District 6201 S Street P. O. Box 15830' Sacramento, California 95813

SUBJECT:

AMENDMENT NO. TO FACILITY OPERATING LICENSE NO. DPR-54 LOW TEMPERATURE OVERPRESSURE PROTECTION The Commission has issued the enclosed Amendment No. to Facility Operating License No. DPR-54 for Rancho Seco Nuclear Generating Station. This amendment revises the facility Technical Specifications in response to your application dated July 16, 1985.

The amendment adds Limiting Conditions for Operation and Surveillance Requirements for the Low Temperature Overpressure Protection System to the facility Technical Specifications. We have corrected certain typographical errors identified.in the basis for the proposed specifications. These corrections were discussed with and agreed to by one of your representatives.

A copy of the Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commission's Monthly Notice.

Sincerely, Operating Reactors Branch No. 4 Division of Licensing

Enclosures:

- 1. Amendment No. to DPR-54

2. Safety Evaluation cc w/ enclosures:

See next page I

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-1 SACRAMENTO MUNICIPAL UTILITY DISTRICT DOCKET NO. 50-312 RANCHO SECO NUCLEAR GENERATING STATION AMENDMENT-TO FACILITY OPERATING LICENSE Amendment No.

License No. DPR-54

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Sacramento Municipal Utility District (the licensee) dated July 16, 1985, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities wil1~be ccmducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; E. The issuance of this amendment is in accordance.with 10 CFR Part 51 of the Commission's' regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-54 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. , are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications, except where otherwise stated in specific license conditions.

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3. This license amendment is effective as of its date of issuance.

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Attachment:

-ChangestotheTechnicalSjecifications ,

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<4 w >> ATTACHMENT TO LICENSE AMENDMENT NO.

'L" 3 FACILITY OPERATING LICENSE NO. DPR-54

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V Replace the following pages,of.the Append'ix A Technical Specifications with'

the. enclosed pages as ind1cated. .The revised pages are identified by Amendment number and contain vertical lines indicating the area of change. A

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I RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS TABLE OF CONTENTS (Continued)

Section Page 3.1.6 Leakage 3-12 3.1.7 Moderator Temperature Coefficient of Reactivity 3-15 3.1.8 Low Power Physics Testing Restrictions 3-15b 3.1.9 Control Rod Operation 3-16 3.2 HIGH PRESSURE INJECTION, CHEMICAL ADDITION AND LOW TDiPERATURE OVERPRESSURE PROTELTION (LTOP) SYSTEMS 3-17 3.3 EMERGENCY CORE COOLING, REACTOR BUILDING EMERGENCY LOULING, AND REALTOR BUILDING SPRAY SYSTEM 5 3-19 3.4 STEAM AND POWER CONVERSION SYSTEM 3-23 3.5 INSTRUMENTATION SYSTEMS 3-25 3.5.1 Operational Safety Instrumentation 3-25 3.5.2 Control Rod Group and Power Distribution Limits 3-31 3.5.3 Safety Features Actuation System Setpoints 3-34 3.5.4 Incore Instrumentation 3-36 3.6 REACTOR BUILDING 3-39 3.7 AUXILIARY ELECTRICAL SYSTEMS 3-41 3.8 FUEL LOADING AND REFUELING 3-44 3.9 Deleted 3.10 SECONDARY SYSTEM ACTIVITY 3-47 3.11 REACTOR BUILDING POLAR CRANE AND AUXILIARY H0IST 3-49 3.12 SH0CK SUPPRESSORS (SNUBBERS) 3-51 3.13 AIR FILTER SYSTEMS 3-52 3.14 FIRE SUPPRESSION 3-53 3.14.1 Instrumentation 3-53 3.14.2 Water System 3-53 3.14.3 Spray and Sprinkler Syrtems 3-50 3.14.4 CO2 System 3-56 iii L .

4 RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation 3.2 HIGH PRESSURE INJECTION, CHEMICAL ADDITION, AND LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEMS Applicability

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Specification 3.2.1 applies to the operational status of the high pressure inje; tion and chemical addition systems. Specification 3.2.2 applies to the

, operational status of the Low Temperature Overpressure Protection (LTOP)

Systems when the RCS temperature falls below 350' F and is not open to atmosphere, which includes the Reactor Vessel head removed, any one of the 4 OTSG manways open , the pressurizer heater bundle removed, or the pressurizer manway removed.

Objective Specification 3.2.1 provides for adequate boration under all operating conditions to assure ability to bring the reactor to a cold shutdown condition. Specification 3.2.2 defines the necessary conditions for preventing an excessive overpressure transient to occur at low temperatures.

Specification 3.2.1 The reactor shall not remain critical unless the following conditions are met:

3.2.1.1 Two pumps capable of suppl /ing high pressure injection are operable (also see Specification 3.3.2).

3.2.1.2 The borated water storage tank and its flow path to the reactor for high pressure injection are operable.

3.2.1.3 A source of concentrated boric acid solution in addition to the borated water storage tank is available and operable. This requirement is fulfilled by tne concentrated boric acid storage tank. This tank shall contain at least the equivalent of 10,000 gallons of 7,100 ppm boron. System piping and valves necessary to establish a flow path for high pressure injection shall also be operable and shall have at least the same temperature as the boric acia storage tank. One associated boric acid pump is operable. The concentrated boric acid storage tank water shall not be less than 70F, and at least one channel of heat tracing shall be operable for this tank's associated piping.

The concentrated boric acid storage tank boron concentration shall not exceed 8,500 ppm coron.

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation 3.2.2 The Low Temperature Overpressure Protection System will require the following conditions:

3.2.2.1 LTOP will be manually enabled prior to the Reactor Coolant System temperature dropping below 350*F during

' plant cooldown.

3.2.2.2 All HPI Systems will be locked out whenever the RCS 1 temperature is below 350*F. This shall be done by opening and tagging the circuit breakers for the four I HP1 Motor-0perated Yalves (Loop A: SFV-23809, SFV-23811; and Loop B: HV-23801, SFV-23812) with the valves in the closed position.

3.2.2.3 The makeup tank water level is to be less than 86 inches.

3.2.2.4 The pressurizer water level will be maintained at or below 220 inches at system pressures above 100 psig and less than 275 inches for pressures less than or equal to 100 psig except during RCS filling and draining.

3.2.2.5 The core flood tank discharge valves are closed and the circuit breakers for the motor operators are racked out before the RCS pressure is decreased to 600 psig.

3.2.2.6 When LTOP is required, only one HPI pump will be operated except during the transition of pumps that will supply Reactor Coolant Pump seals and makeup flow for the RCS.

Bases The makeup and purification system and chemical addition s control of the reactor coolant system boron concentration.gstems Thisprovide is normally accomplishco by using either the makeup pump or one of the two high t

pressure injection pumps in series with a boric acid pump associated with the concentrated boric acid storage tank. The alternate method of boration will be the use directly fromofthe the borated makeupwater.

or highstorage pressure injgetion pumps taking suction tank.

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The quantity of boric acid in storage from either of the two above-mentioned sources is sufficient to borate the reactor coolant system to a 1 percent suberitical margin in the cold condition (70F) at the worst time ~in core life with a stuck control rod assembly. The maximum required is the equivalent of 9586 gallons of 710') ppo boron. This requirement is satisfiea by requiring a minimum volume of 10,000 gallons of 7100 ppo in the concentrated borated acia 3-17a

f RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation storage tank during critical operations. The minimum volume for the borated water storage tank (390,000 gallons of 1800 ppm bo.'on), as specified in section 3.3, is based on refueling volume requirements and easily satisfies the cold shutdown requirement. The specification assures that the two supplies are available whenever the reactor is critical so that a single failure will not prevent boration to a cold condition. The minimum volumes of boric acid solution given include the boron necessary to account for xenon decay. -

The quickest method allows for the necessary boron addition in less than one hour. The primary method of adding boron to the primary system is to pump the concentrated boric acid solution (7100 ppm boron, minimum) into the makeup tank using the 50 gpm boric acid pumps. Using only one of the two boric acid j pumps, the required volume of boric acid can be injected in less than 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The alternate method of addition is to inject boric acid from the borated water storage tank using the high pressure injection pumps.

Concentration of boron in the concentrated boric acid storage tank mAy be higher than the concentration which would crystallize at ambient conditions.

For this reason and to ensure that a flow of boric acid is available when needed, this tank and its associated piping will be kept above 70F (30F above the crystallization temperature for the concentration present). Once in the high pressure injection system, the concentrate is sufficiently well mixed and diluted so that nomal system temperatures ensure boric acid solubility. The value of 70F is significantly above the crystallization temperature for a solution containing 12,200 ppm boron. l The Low Temperature Overpressure Protection System (LTOP) consists of both an I active and a passive subsystem. The active subsystem utilizes the ElectroMatic Operated Valve (EMOV) which provides overpressure protection ,

during normal plant operation. The EMOV actuation circuitry has been modified '

to provide a second setpoint (500 psig) that is used during low-temperature operations. The low setpoint is manually enabled at 350*F by positioning a key-operated switch in the Reactor Control Room. An alarm will sound in the Reactor Control Room if the reactor coolant pressure falls below 450 psig and the key-operated switch is not selected for low-temperature operation. After selection of low temperature operation, additional alams will occur if either HPI pump breaker is not racked out; if either Seal Injection flow is greater than 42 gpm or makeup flow is greater than 135 gpm; if HPI valves are not closed; and if the EMOV block valve HV-21505 is not open. The passive subsystem is based on the plant design and operating philosophy that precludes the plant from being in a water solid condition (except for system hydrotests). The Rancho Seco Reactor Coolant System always operates with a steam or gas space in the pressurizer; the , steam bubble is replaced with l nitrogen during plant cooldown when system pressure is reduced. The requirements for a maximum. pressurizer level provides for a sufficient vapor space in the pressurizer to retard the rate of increase of RCS pressure, as '

compared to a water solid system for all mass and heat input transients. In this manner, the operator will have time to recognize that a pressure transient is in progress and take action to mitigate the incident. For these ,

reasons the pressurizer water level will be maintained at or below 220. inches l J

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation at-system pressures above 100 psig and less than 275 inches for system pressures less than or equal to 100 psig. The only exception to these requirements will be when the RCS is being filled or drained. During the filling proce'ss the pressurizer is filled with water up to the 320 inch level. The High Point Vents are upened and nitrogen is injected into the pressurizer hence forcing the coolant into the loops. Subsequently, the High Point Vents are closed, a steam bubble is drawn and the nitrogen is released through the pressurize'r vents. During the draining process, the pressurizer is depressurized, the High Point Vents and RCS Hot Leg Vents are opened thus reducing the RCS to atmospheric pressure. The loop coolant level and pressurizer level equalize at 320 inches and draining can then take place.

In conjunction with the enablement of LTOP at 350*F and the subsequent restriction on pressurizer level, analysis has shown that the HPI system is not needea when RCS temperature falls below 350"F. The requirement for a maximum makeup tank level limits the mass input available from the tank should the makeup valve fail open.

When LIOP conditions are required, only one of the two HPI pumps or the makeup pump will be allowed to operate Rancho Seco normally operates with the makeup pump supplying makeup and seal injection. Should, in the unlikely event, degradation of this pump occur while in the' LTOP mode, it would be necessary to start one of the HPI pumps before stopping the makeup pump. This scenario would result in a brief overlap time period where an increase in flow through the makeup line would occur. However, because the operator is aware of the LTOP conditions, it is expected that this brief transition stage would not significantly increase the level of the pressurizer and the probability of an over-pressurization incident.

Separate power supplies are provided for the EMOV circuitry and LTOP alarms which alert the operator of an overpressurization event so that a single power source failure will not disable the ENOV and LTOP alarms. This assumes the operator is alerted so he can take action to terminate an event even if the EMOV is disabled. These alarms are high pressurizer level, high - high pressurizer level, and high makeup tank water level.

REFERENCES 1

FSAR subsections 9.2 and 9.3.

2 FSAR Figure 6.2-1.

3 Technical Specification 3.3.

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", TABLE 4.1-1 (Continued)

G INSTRUMENT SURVEILLANCE REQUIREMENTS Channel Description Check Test Calibrate Remarks

57. Voltage Protection S(l) M n (1) Compare voltmeter readings

a. Undervoltage 3 g

b. Overvoltage 11 R

c. Time Delay A

58. Low Temperature Over-pressure Protection N/A (2) R (2) Prior to cooldown hs E 2 (EMOV) $@

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l 5 = Each shift M = Monthly P = Prior to each startup If not done previous week 2 m

D = Daily Q = Quarterly R = Once during the refueling Interval "

E W = Veckly SY= Semiannual R 5

RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Surveillance Standards TABLE 4.1-2 MINIMUM EQUIPMENT TESI FREQUENCY Item Test frequency

1. Control rocs Rod drop times or all Each refueling snutdown full length rods

2. Control rod Movement of each rod Every two weeks ,

movement

3. Pressurizer code Setpoint Note 3 safety valves

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4. Main steam safety Setpoint Note 3 valves

5. Refueling system Functional Each refueling interval interlocks prior to handling fuel.

6. Turbine steam stop Movement of each valve Monthly valves

7. Reactor coolant Leakage Calculated inventory system weekly Leakage check daily.

8. Charcoal and high Charcoal and HEPA Each refueling interval and efficiency filters filter for iodine at any time work on filters and particulate could alter their integrity removal efficien-cies. 00P test on HEPA filters.

Freon test on charcoal filter units.

9. Fire pumps and Functional Monthly power supplies

10. Reactor Building Functional Each refueling isolation trip interval

11. Spent fuel Functional Each refueling '

cooling system interval prior to fuel handling

12. Turbine Overspeed Calibration Each refueling Trips interval 4-8

I RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Surveillance Standards TABLE 4.1-2 MINIMUM EQUIPHtNT IEST FREQUENCY ltem Test

13. Internals Vent Manual actuation,1 Each refueling Valves remote visual inspection 2 interval verify valve not stuck open i

14. Low Temperature Functional 4 Prior to less than Overpressure 350*F Protection (EMOV) l 1.

Verifying through manual actuation that the valve is fully open with a force of 1 00 4 lbs. (applied vertically upward).

2. Check visually accessible surfaces to evaluate observed surface irregularities.

3-Tested in accordance with Section XI of the ASME Boiler and Pressure Yessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the NRC pursuant to 10 CFR 50, Section 50.55a(g)(6)(f).

4 EMOV block valve closed during test.

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.

TO FACILITY OPERATING LICENSE NO. DPR-54

' SACRAMENTO MUNICIPAL UTILITY DISTRICT RANCHO SECO NUCLEAR GENERATING STATION DOCKET NO. 50-312

.I. INTRODUCTION A. DESCRIPTION OF PROPOSED ACTION The proposed action would amend Appendix A of the Technical Specifications for the Rancho Seco Nuclear Generating Station (the facility) by adding Limiting Conditions for Operation and Surveillance Requirements for the Low Temperature Overpressure Protection (LTOP) System.

Notice of Consideration of Issuance of Amendment to License and Proposed No Significant Hazards Consideration Determination and Opportunity for Hearing related to the requested action was published in the Federal Register on . No comments or requests for hearing were received.

B. BACKGROUND INFORMATION Appendix G of 10 CFR 50 sets forth Fracture Toughness Requirements applicable to ferritic materials of pressure-retaining components of the reactor coolant pressure boundary. These requirements are most restrictive at lower temperatures (i.e. at cold shutdown ,

temperatures, as opposed to those occurring during power operation).

As a result of several significant pressure transients that had previously occurred during cold shutdown conditions at operating reactors, the NRC, by letter dated August 11, 1976, requested the Sacramento Municipal Utility District to evaluate the susceptibility of the facility to overpressurization events and propose interim and permanent modifications to plant systems and procedures as necessary to reduce the likelihood and consequences of such events. The licensee initially responded to this request by letter dated October 14, 1976. Subsequently, additional correspondence between the NRC and the licensee culminated in issuance of the staff's Safety Evaluation transmitted to the licensee by letter dated June 29, 1984 (the SE). One of the findings of this SE was that certain administrative controls incorporated in plant operating procedures to prevent low temperature overpressurization events should be required by the Technical Specifications. Another finding was that test requirements for the LTOP System should be included in the Technical Specifications.

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i One item unresolved by the' SE was the proper pressure limit- for the LTOP System. The licensee had proposed a setpoint of 500 psig; but at the time the SE was issued, the' staffs had insufficient basis for concluding this value met' regulatory requirements. Subsequent discussions and correspondence between the licensee and the staff finally supported the conclusion that 500 psig was an acceptable setpoint. This was documented in'the NRC letter to the licensee dated February 25, 1985. This'1etter also stated that inasmuch as all of the staff's concerns regarding the LTOP System were resolved, the licensee should propose Technical Specifications for the system.

The present action involves evaluation of the Technical Specifications proposed by the licensee in response to this request.

The administrative controls listed in the staff's SE were as follows:

1. The Rancho Seco Overpressure Protection System is to be manually enabled prior to the reactor coolant system temperature dropping below 350*F during plant cooldown. An alarm will sound in the control room if the system is not enabled or if the PORV isolation valve is not open when the RCS pressure drops below 500 psig.

2. The plant is to be operated with a steam or nitrogen blanket in the pressurizer at all times except for system hydrostatic tests. The pressurizer water level is maintained at or below the high level alarm at system pressures above 100 psig and less than the high high level alarm for pressures less than or equal to 100 psig.

3. The makeup tank water level is to be less than the high level alarm.

4. The core flood tank discharge valves are closed and the circuit breakers for the motor operators are " racked out" before the RCS pressure is decreased to 600 psig.

5. During a plant cooldown the Engineered Safeguard Actuation of  ;

the llPI System is bypassed at 1650 psig. Prior to going below 350*F, the circuit breakers for the four IIPI motor operated l valves are tagged open with the valves in the closed position. l This is accomplished by opening and tagging the selector switch in the Control Room and locking and tagging the breakers located at the Motor Control Center. The Operator will receive an alarm in the Control Room if the overpressure protection l system is enabled and any of the four llP injection valves is in the open position.

6. The llPI test procedure ensures that only one (1) llPI pump is tested at a time and that no other llPI pump is operating during the test.

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C. SCOPE OF REVIEW This review has considered only the changes in the facility technical specifications requested by the licensee. It has not l considered those portions of the technical specifications for which changes were not requested. In performing this review we have

considered whether the changes would reduce any of the operational l

or administrative requirements implemented at the facility. Whether r or not such a reduction was proposed, we have evaluated whether the change would: (1) increase the probability or consequences of accidents considered in the FSAR, (2) create the possibility of an accident not considered in the FSAR, or (3) reduce the margin of safety as defined in the basis for any technical specification. In addition, we have considered the degree to which the licensee's proposal conforms to the administrative controls and surveillance guidance provided in the staff's Safety Evaluation.

II. EVALUATION Introduction. We note at the outset, the licensee's submittal generally conforms to the administrative controls described in the staff's SE as set forth above. Certain differences are noted, however, and these are addressed in the following evaluation. The licensee's submittal also involves certain changes to some of the existing text of the Technical Specifications. These changes, however, are editorial in nature and are i needed to incorporate the new requirements into an existing section of the Technical Specifications. These changes, however, are addressed. As an aid to understanding the proposed specifications, it should be noted the nomenclature used by the licensee in this submittal differs somewhat from common usage. Specifically, the pressurizer relief valve commonly referred to elsewhere as the PORV, is referred to in the licensee's submittal as the EMOV (ElectroMatic Operated Valve). This understanding is necessary because the PORV/EMOV is the component utilized to limit the Reactor Coolant System (RCS) pressure during low temperature operations.

Specification 3.2.

General. This specification presently is titled and addresses the liigh Pressure Injection and Chemical Addition Systems. The licensee has chosen this specification as the location for inclusion of the operational requirements applicable to the LTOP System. Accordingly, the licensee proposes to change the title to liigh Pressure Injection, Chemical Addition, and Low Pressure Overpressure Protection (LTOP)

Systems. The licensee also proposes to renumber and re-format this section by assigning Section 3.2.1 to the fligh Pressure Injection and Chemical Addition Systems; and Section 3.2.2 to the LTOP Ilystem. We conclude these are editorial changes and are acceptable.

Applic1bility. The licensee proposes to revise this section of the specification to add the applicability requirements for the LTOP System.

The licensee states the specification will apply to the LTOP System when the Reactor Coolant System (RCS) temperature falls below 350*F and is not open to the atmosphere. The licensee also states the specification will not apply when the reactor vessel head is removed, one or more steam

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generator or pressurizer manways are'open or a pressurizer heater bundle l- is removed. We note the temperature regime over which the licensee c proposes to require this system, corresponds'to that previously accepted l by the staff; therefore, this portion of the proposed specification is acceptable. We also note the LTOP System is needed to protect against overpressurization events at reduced temperatures when the Reactor Coolant System is closed. If' the system is open to. the atmosphere (with a significant opening), however, the LTOP System is not needed because system pressure cannot be significantly increased. We further note the j above conditions proposed by the licensee for when the LTOP System will l not be required, are such that significant openings will exist in the RCS l (the smallest opening is about 18-inches in diameter according to a licensee representative). Accordingly, we find the specific exceptions to applicability proposed by the licensee acceptable.

Objective. The licensee proposes to revise this section to add the objective applicable to the LTOP System and to reflect the organization of Specification 3.2. We conclude these are editorial changes and are acceptable.

i Specification 3.2.2 l

The licensee proposes to add this specification to address the l operational requirements applicable to the LTOP System. The acceptability of each provision of this proposed specification is addressed below:

3.2.2.1. This paragraph is proposed by the licensee in response to the staff position stated in I.B.1, above. The licenace's proposed specification would require the LTOP System to be manually enabled before the RCS temperature is decreased below 350'F. This conforms to the cited staff position, and is therefore acceptable. As indicated below, the licensee has also provided information indicating the alarms prescribed by the staff position have been installed. Accordingly, we conclude the licensee has acceptably implemented the technical specification and hardware provisions of this staff position.

3.2.2.2. This paragraph is proposed by the licensee in response to the staff position stated in I.B.5, above. It has not been proposed by the licensee to require bypassing Engineered Safeguard Actuation of the Ifigh Pressure Injection (llPI) system below 1650 psig because such bypassing is an operational necessity (otherwise llPI actuation would occur during each shutdown). Accordingly, we find the licensce's omission of this provision acceptable. Regarding the other provisions of the staff position, the licensee proposes to meet these by requiring that all !!PI Systems be locked out whenever the RCS temperature is below 350*F, and requiring the opening and tagging of the circuit breakers serving a specified motor-operated valve in each IIPI injection line, with the valve in the closed position. Although not stated in the specification, the licensee states this will be implemented by providing alarms for the following conditions: (1) LTOP not enabled when RCS temperature la below 450'F; and, when LTOP is enabled, additional alarms when (2) circuit breakers for the llPI pumps are not racked out; (3) seal injection flow is greater than 42 gpm or makeup flow is greater than 135 gpm; (4) valves 11.

5 IIPI injection lines are not closed and (5) the EMOV block valve is not open.

Regarding the above provisions, it is noted the facility is equipped with three identical high pressure pumps. Two of these are designated liigh Pressure Injection pumps and one is designated the Makeup pump. Any one of the three, however, can serve either function. It is also noted that although the Engineered Safeguards Actuation of IIPI is disabled below 1650 psig (with the two llPI pump breakers " racked-out" and alarmed below 350*F), the Makeup Pump (or one of IIPI- Pumps if the Makeup Pump is inoperable) is continued in operation during plant cooldown until the RCS temperature reaches about 200*F. This is done to permit addition of coolant to compensate for coolant shrinkage during reactor cooldown, and to permit continued reactor coolant pump seal injection. Based on discussions with the licensee, continued seal injection is needed to prevent imposition of significant thermal transients on the reactor coolant pump seal region (in the absence of seal injection below 350'F,

• regions previously cooled by seal injection, would experience rapid heating by the adjacent hot reactor coolant). Based on this mode of operation, the licensee has provided an alarm on the seal injection line if its flow exceeds 42 gpm, and on the makeup line if its flow exceeds l

135 gpm. Since these are substantially the same values assumed for the safety evaluation submitted by the licensee, and accepted by the staff, we conclude these alarm levels are acceptable.

Regarding the makeup flow rate alarm, it is noted the licensee has committed to provide a bypass line around the main valve used to control makeup flow following completion of Operating Cycle 7. This will permit l closing the main valve and using the bypass line to limit makeup flow.

The licensee states the bypass line will be designed to limit the makeup flow to 138 gpm, which is the value found acceptable by the staff.

i Therefore, after Cycle 7, the limit on makeup flow rate will be provided ,

l by a hardware modification instead of the present (alarmed) l administrative limit.

! l l In this proposed specification, the licensee states the circuit breakers will be opened and tagged for the following ilPI valves which will be l

placed in the closed position: SFV-23809, SFV-23811,llV-23801, l

SFV-23812. Our reivew of the facility Piping and Instrumentation '

Drawings indicates these valves will isolate the lipI function for this

, plant condition. We therefore, find the licensee's selection of these l valves acceptable.

l Based on the foregoing, we conclude this proposed specification is in substantial conformance with the staff position stated in paragraph l 1.B.5, above, and is therefore, acceptable.

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! 3_. 2 . 2_. ;) . This proposed specification would require the makeup tank water ,

level to be Icas than 86-inches when the I.T0p System is required.  !

Inasmuch as 86-inches corresponds to the setpoint of the high 1cvel l alarm, this proposed specification conforms to the staff position stated in I.ll.3 above, and is acceptable, ,

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6 3.2.2.4. This proposed specification is intended to implement the staff position on pressurizer level limits (paragraph I.B.2, above). We find the specific levels (in inches) proposed by the licensee correspond directly to the setpoints for the level alarms specified in the staff position. Accordingly, we find this element of the proposed specification acceptable.

The licensee does not explicitly address the requirement to maintain a steam or nitrogen blanket in the pressurizer at all times except during hydrostatic testing - as specified by the staff position. Maintenance of 1 a steam or nitrogen blanket in the pressurizer, however, has been and is a fundamental characteristic of B&W reactor operation. In addition, the proposed limits on pressurizer level effectively require the maintenance r of a steam or nitrogen blanket. Therefore, we conclude explicit restatement of this principle of operation in the technical

specifications is not required. Accordingly, we find this element of the proposed specification acceptable.

The licensee proposes one exception to the pressurizer level limits specified by the staff. This exception relates to the allowable pressurizer level while filling and draining the RCS. For these conditions the licensee proposes to allow a level of 320-inches (the maxistun indicator level - at which there is still in excess of 42 inches of hemispherical gas space in the pressurizer). The justification for L the higher allowable levels during filling and draining is described by the licensee in the Basis for the proposed specification. In particular, i because, during filling of the RCS, coolant is pushed (by nitrogen l pressure) from the pressurizer to portions of the RCS which are at higher l elevations, a high pressurizer level is needed to provide the volume of l water necessary to fill the RCS hot leg " candy canes". Accordingly, the

! licensee fills the pressurizer to the maximum indication level (320 inches) for this operation. Similarly, during draining, even though a l low pressurizer level is initially established, opening the high point vents in the RCI and pressurizer, allows the water level to equalize at l about the 320 inch pressurizer level. Following this, the balance of the

! draining procedure may proceed. Therefore, because a high pressurizer

! Icvel (about 320 inches) is needed for both draining and illling i operations, because these are normal operational sequences used on

numerous instances in the past without incident, and because a steam or

I nitrogen blanket or atmosphere is maintained in the pressurizer during these operations, we conclude the exception to the staff position l proposed by the licensee for draining and filling operations is acceptable.

Based on the above, we conclude the specification proposed by the licensee to meet this t,taff position is acceptable.

3.2.2.5. This proposed specification has been submitted to conform to the staf f position stated in paragraph I.B.4, above. Inasmuch as the l l licensee's proposal for this item is substantially identical to the staff '

l position, we conclude the proposed specification is acceptable.

3.2.2J . This proposed specification is intended to respond to the staff posltion in paragraph I.B.6. The staf f position states the lip! test l

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- 7 procedureshouldensurethatonlyone!!PIpubpistestedatatimeand that no other HPI pump is operating during the test. The specification proposed by the licensee would extend the require nent for single pump operation beyond the single activity of testing to all' situations when the LTOP System is required. At the same time, the li'ensee c anticipates the situation where it would be necessary'to switch from one pump to another, and specifically provides .for a transition period during which one pump is shutting down and another is starting up. The licensee justifies the transition period on the basis of the need to maintain seal injection for the reactor coolant pumps and to maintain makeup flow during cooldown (as discussed in connection with proposed specification 3.2.2.2, above). We agree these goals provide a reasonable basis for providing for a transition period. We also note that. because alarms are provided to indicate excessive seal injection or makeup flow, there is a reasonable basis for concluding it is unlikely the transition period will be abused. Based on the foregoing, we conclude the specification proposed by the licensee satisfactorily meets the intent of the staff position and is, therefore, acceptable.

Basis.

The licensee proposes to amend the Basis for Specification 3.2 by adding the Basis for the specifications applicable to the LTOP System. Our review of the proposed Basis indicates it is in substantial conformance with the staff's positions stated in the SE. Accordingly, we find the proposed revised Basis acceptable. We have corrected certain typographical errors identified in this section. These corrections were i discussed with and agreed to by a representative of the licensee.

Table 4.1-2, Minimum Equipment Test Frequency.

The staff's Safety Evaluation transmitted by letter dated June 29, 1984, '

stated that testing of the LTOP System should be performed to assure operability of the system electronics prior to each shutdown and that a test for valve operability should be conducted as specified by Section XI of the ASME Boiler and Pressure Vessel Code. The licensee's proposed revision to this Table would add a portion of these test requirements by i l requiring functional testing of the LTOP EMOV prior to the RCS temperature being reduced below 350*F, with the EMOV block valve closed.

Inasmuch as ASME testing requirements are being addressed by a separate licensing action, we conclude the licensce's proposed revision conforms to the staff position regarding non-ASME LTOP System testing and is l

acceptable.

Table 4.1-1._ instrument Surveillance Requirements.

l The licensee proposes to revise this table to add surveillance

! requirements for the LTOP System. These include the functional test i described above, to be performed prior to cach cooldown, and calibration i to be performed during each refueling outage. As noted above, we find the test requirements acceptable; and we find the proposed calibration frequency to be same as that required for other systems important to safety. Accordingly, we conclude the proposed revisions to this table are acceptable.  !

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• 8 III. CONCLUSIONS

! Environmental Consideration i

This a.nendment involves a change in the installation or use of a facility

component located within the restricted area as defined in 10 CFR Part

20. The staff has determined that the amendment involves no significant increase in the amounts'of any effluents that may be released offsite, j and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding.

Accordingly, this amendment meets the eligibility criteria for l categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

Conclusion We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendment will not be inimical to l common defense and security or to the health and safety of the public.

l Date:

Principal contributor:  ;

G. Zwetzig  !

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