ML20196J534
| ML20196J534 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/24/1988 |
| From: | DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20196J531 | List: |
| References | |
| NUDOCS 8807060404 | |
| Download: ML20196J534 (12) | |
Text
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2 ATTACHMENT I
-PROPOSED TECHNICAL SPECIFICATION CHANGES-t a
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c 8807060404 880624 PDR ADOCK 05000369 PNU.
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TABLE 4.3-2 (Continued) 2
[NGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION
~
E3 SURVEILLANCE REQUIREMENIS 5
N?
TRIP ANALOG ACTUATING MODES CHANNEL DEVICE MASTER SLAVE FOR WHICH c:
25 CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION RELAY RELAY SURVEILLANCE DI FUNCTIONAL UNIT CHECK CALIBRATION TEST TEST LOGIC TEST TEST TEST IS REQUIRED
{
- 7. Auxiliary feedwater E
a.
Manual Initiation N.A.
N.A.
N.A.
R N.A.
N.A.
N.A.
1,2,3 b.
Automatic Actuation N.A.
N.A.
N.A.
N.A.
M(1)
M(1)
Q 1,2,3 Logic and Actuation Relays c.
Steam Generator Water S R
H N.A.
N.A.
N.A N.A.
1, 2, 3 Level--Low-Low w
d.
Auxiliary Feedwater N.A.
R N.A.
R N.A.
N.A.
N.A.
1, 2, 3 3:
Suction Pressure-Low i'
e.
Safety Injection See Item 1. above for all Safety Injection Surveillance Requirements w
f.
Station Blackout N.A.
N.A.
N.A R
N.A.
N.A.
N.A.
1, 2, 3 g.
Trip of Main feedwater N.A.
N.A.
N.A.
R N.A.
N.A.
N.A 1, 2 Pumps
- 8. Automatic Switchover to Recirculation ggp S$
RSWI Level YWA-R M
N.A.
N.A.
N.A.
N.A.
1, 2, 3 l
"5 mO
- 9. Loss of Power aa 4 kV Emergency Bus N.A.
R N.A.
M N.A.
N.A.
N.A 1, 2, 3, 4 cI!I undervoltage-Grid
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gpy; Degraded Voltage 22
- 3. 3.
ee
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TABLE 4.3-7 g
ACCIDENT MONITORING INST M UlTATIUR SURVEILLANCE REQUIREMENTS S
CHANNEL CHANNEL M
INSTRUMENT CHECK CALIBRATION 1.
Containment Pressure M
R E
]
2.
Reactor Coolant Temperature - T and TCOLD ( de Range)
M R
H0T 3.
Reactor Coolant Pressure - Wide Range M
R
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{
4.
Pressurizer Water Level M
R S.
Steam Line Pressure M
R m
j 6.
Steam Generator Water Level - Narrow Range M
R 7.
Refueling Water Storage Tank Water Level X NA-R l
8.
Auxiliarjs Feedwater Flow Rate M
R 9.
Reactor Coolant System Subcooling Margin Monitor M
R g
10.
PORV Position Indicator M
R 11.
PORV Block Valve Position Indicator M
R 12.
Safety Valve Position Indicator M
R 13.
Containment Water Level (Wide Range)
M R
14.
In Core Thermocouples M
R 15.
Unit Vent - High Range Noble Gas Monitor M
R (High-High Range - EMF-36) gg 16.
Steam Relief - High Range Monitor M
R gg (Unit 1 - EMF-24, 25, 26, 27) gg (Unit 2 - EMF-10, 11, 12, 13) 17.
Containment Atmosphere - High Range Monitor M
R (EMF-Sla or 31b) 22 O O 18.
Reactor Vessel Level Instrumentation 2
7 Wide-Range D narmc. Head CD/P3h e M
R
)
gg a.
3 3
ibn3 4
)( d.O.
R C
l' b.
-Marr= Mga Loww EE C
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TABLE 4.3-8
[
RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREM C
ANALOG 5
CHANNEL CHANNEL SOURCE CHANNEL OPERATIONAL CHECK CHECK CALIBRATION TEST E
INSTRUMENT 1.
Radioactivity Monitors Providing Alarm And Automatic Termination of Release Waste Liquid Effluent Line (EMF-49)
D P
R(3)
Q(1)
{
a.
N b.
Containment Ventilation Unit D
M R(3)
Q(1)
Condensate Line (EMF-44) 2.
Radioactivity Monitors Providing Alarm But Not Providing Automatic Termination of Release Conventional Wastewater Treatment Line D
M R(3)
Q(2)
(EMF-31)
R 3.
Continuous Composite Samplers And Sampler
[
Flow Monitor Containment Ventilation Unit E
a.
D N.A.
R Q
Condensate Line b.
Conventional Wastewater Treatment Line D
N.A.
R Q
4.
Flow Rate Measurement Devices Waste Liquid Effluent Line D(4)
N.A.
R A NA.
a.
b.
Discharge Canal Minimum Flow Interlock 0(4)
N.A.
N.A.
Q Containment Ventilation Unit Condensate D(4)
N.A.
R Q
c.
Line d.
Conventional Wastewater Treatment Line D(4)
N.A.
R Q
REACTOR COOLANT SYSTEM 3/4.4.3 PRESSURIZER LIMITING CONDITION FOR OPERATION The pressurizer shall be OPERABLE with a water level of less than or 3.4.3 equal to 92% (1600 cubic feet), and at least two groups of pressurizer heaters each having a capacity of at least 150 kW.
APPLICA8ILITY:
HODES 1, 2, and 3.
ACTION:
With one group of pressurizer heaters inoperable, restore at least two groups to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT a.
STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, With the pressurizer otherwise inoperable, be in at least HOT b.
STANOBY with the Reactor trip breakers open within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN within the followfng 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
SURVEILLANCE REQUIREMENTS 4.4.3.1 The pressurizer water level shall be determined to be within its limit at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The capacity'of each of the above required groups of pressurizer 4.4.3.2 heaters shall be verified by energizing the heaters and measuring circuit current at least once per 92 days.
4.'.3.3 The :::rg:ncy perer :epply fer the pr-seur4 2e* haat-*e sh"!' ba Ammanetem+mA ADCDADtC me 1 emet anpa nec 19 mnnthe hu manuallu tennefaae4aa hEYES'*-5E~EhiA.$EEE555555 E:EYiin:[ pEU: : pply':n3 :n:Thi:ingth:
5 :ters.
McGUIRE - UNITS 1 and 2 3/4 4-9
REACTOR COOLANT SYSTEM 3/4.4.4 RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.4 All power-operated reliei valves (PORVs) and their associated block valves shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, and 3.
ACTION:
a.
Witn one or more PORV(s) inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the PORV(s) to OPERABLE status or close the associated block valve (s) and remove power from the block valve (s); othenvise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, b.
With one or more block valve (s) inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> either restore the block valve (s) to OPERABLE status or close the block valve (s) and remove power from the block valve (s) or close the PORV and remove power from its assottated solenoid valve; otherwise, be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COL'O SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
g c.
The provisions of Specification 3.0.4 are not. applicable.
SyRVEILLANCEREQUIREMENTS 4.4.4.1 In addition to the requirements of Specification 4.0.5, each PORV shall be demonstrated OPERABLE at least once per 18 months by:
a.
Performance of a CHANNEL CALIBRATION, and b.
Operating the valve through one complete cycle of ' full travel.
4.4.4.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by operating the valve through one complete cycle of full travel unless the block valve is closed with power removed in order to meet the requirements of ACTION a. in Specification 3.4.4.
4.4.4.3 Th: = rgency pcicr ;upply for the PORV: :nd bicck valve; : hall be do;ca:trated OPERACLE et lesst once per 10 mcaths by.
"= lly tran; ferring motive end control pe-. f c A
.~..~1 Le a.
the = rgency pcsec supply, end b.
Op; rating the valvc; through c.
- plet cycle of full trovc!.
McGUIRE - UNITS 1 and 2 3/4 4-10
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ATTACIDfENT 2 JUSTIFICATION AND SAFETY ANALYSIS
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I-Introduction The proposed changes ' to the McGuire Nuclear Station Technical Specifications involve the deletion of various surveillance requirements.
In each case, which will be discussed in more detail, the surveillance requirement is not appropriate under as-built plant conditions, or is not useful under normal operating conditions.
RWST Level, RVLIS The proposed changes to Tables 4.3-2 and 4.3-7 seek to delete channel checks for the Refueling Water Storage Tank (RWST) narrow range level and for the Reactor. Vessel -Level - Indication System (RVLIS) lower range as these requirements are of questionable value.
The RWST' narrow range level and the RVLIS lower range are two examples where the required surveillance is not useful under normal operating conditions.
The required surveillance, a channel check, is by definition a qualitative assessment of channel behavior during operation by observation; including, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels.
measuring the same parameter.
The surveillances in question for these instruments is a channel check, every twelve hours on RWST level automatic switchover to recirculation per the Engineered Safety Features Actuation Sys tern Instrumentation Surveillance Requirements. Table 4.3-2, and monthly channel checks on the RWST level and the RVLIS per the Accident Monitoring Instrumentation Surveillance Require-ments. Table 4.3-7.
The problem arises as these instruments are over-ranged (offscale high) or the indication is invalid during normal operation.
Recently, the validity of channel checks of over-ranged instrumentation has been questioned, so McGuire began to examine alternatives to provide valid checks of the instrumentation.
The alternatives examined included alternative surveillances, instrument loop modification, or deleting the surveillance requirements.
No practical alternatives were found to the surveillances since it would be expected that the instrument would be over-ranged.
This instrumentation would only be useful in a post-accident or shutdown situation.
The RWST level presently requires a monthly analog ch.innel operational test and both instruments require eighteen month channel calibrations.
These additional surveillance requirements ensure the operability and accuracy of these instruments.
The possibility of modifying the instrument loops has been examined and determined not to be practical.
The instruments are only used in post-accident situations, and are expected to be overranged during normal operations.
Modifying the instrument to permit channel checks on these inscruments is not a practical solution as these instrueents are required to function over a narrow range and any modification would either affect this range or not give a valid indication of instrument condition.
Additionally, these instruments have proven to be very reliable.
For the period April 1987 through February 1988, the following maintenance record has been complied:
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RWST Level (3 channels per unit)
UNIT 1:
(13 Functional Checks) One channel required one recali-bration UNIT 2:
(10 Functional Checks) No recalibrations required RVLIS (2 channels per unit)
UNIT 1:
(17 Functional Checks) No recalibrations required UNIT 2:
(15 Functional Checks) One channel required one recali-bration.
The reliability of these instruments obviates the need for semi-daily or monthly channel checks on this instrumentation.
These channel checks may be eliminated without compromising dependability or accuracy of the instruments.
Liquid Effluent Monitoring The proposed change to Table 4.3-8 is to delete the surveillance requirement for the quarterly analog channel operational test for the waste liquid effluent line flow rate measurement device. This surveillance requirement, as discussed below, is not necessary.
Specification 4.3.3.8 with associated Table 4.3-8 Item 4.a requires an "Analog Channel Operational Test" to be performed quarterly on the waste liquid effluent line flow rate measurement device.
By definition, the "Analog Channel Operational Test" includes verification of operability of alarms, interlocks, and trip functions and shall include adjustments as necessary.
The instrument loops in question, designated OWMLP5130 and OWMLP5140, have none of the Lbove functions associated with the loops.
In order to comply with the specification, a "Channel Calibration" has been performed quarterly which involves an adjustment of the channel such that response is within required accuracy.
The channel calibration is more extensive than the analog channel operational test and is required on the instrumentation on an eighteen month interval by the same specification.
These instruments have also proven reliable.
For the period March 1987 through February 1988, these instruments (two channels, common to both units) compiled the following record:
Functional Checks:
13 Reca11brations:
2 (one per channel) l Other problems:
1 (chart recorder problems on one channel)
As the loops have no associated alarm, interlock, or trip functions, this surveillance requirement (quarterly analog channel operational test), becomes
' either a meaningless surveillance, or a redundant channel calibration.
In either case, the quarterly surveillance should be deleted in favor of the existing 18 month surveillance requirement of a channel calibration.
Therefore, the deletion of this requirement is virtually administrative in nature.
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Emergency Power Sources For Pressurizer Heaters, PORV's, and Block Valves The proposed changes to Specifications 3/4.4.3 and 3/4.4.4 are to delete inappropriate surveillance requirements for the pressurizer heaters, power operated relief valves (PORVs), and the pressurizer PORV block valves.
The proposed changes would delete surveillance requirements 4.4.3.3 and 4.4.4.3 relating to the emergency power supplies for the pressurizer heaters, PORVs, and block valves.
The surveillance requirements for these components specify to verify the operability of the emergency power supplies on an eighteen month basis by manually transferring power from normal to emergency and verifying that the equipment functions.
This requirement is not necessary, and is in fact, inappropriate, as each of these components is permanently connected to an emergency power source.
These surveillance requirements are in the Specifications as a result of being carried in from NUREG-0452, Standard Technical Specifications for Westinghouse Pressurized Water Reactors, Revision 4.
The requirements may be traced back to Mr.
D.G. Eisenhut's July 2, 1980 letter to all pressurized water reactor licensees which provided example Specifications for the implementation of TMI Lessons learned requirements, including emergency power supply requirements for pressurizer relief and block valves and pressurizer heaters.
The requirements of Mr. Eisenhut's letter and other TMI requiremants were clarified and consolidated into NUREG-0737 issued October 31, 1980.
Section II.E.3.1 of NUREG-0737 required pressurizer heaters to have installed capability to draw power from emergency power supplies.
Section II.G.1 of NUREG-0737 requires that the pressurizer PORVs and the PORV block valves be capable of being powered from an emergency power source.
As described in the McGuire Final Safety Analysis Report, Section 5.5.10.2.2, the pressurizer heaters are powered through the redundant 600 VAC essential auxiliary power system, one heater group per power train.
The PORV block valves also receive power from the 600 VAC essential auxiliary power system as described in FSAR Section 5.5.10.2.2.
The 600 VAC essential auxiliary power system receives power from the diesel generators in the eve'nt of a station blackout, as described in the FSAR, Section 8.3.1.1.6.
The NRC has reviewed McGuire's design for power supply to the pressurizer heaters and associated controls.
This review is documented in NUREG-0422, Supplement 4 (SER for McGuire), January 1981, in which the NRC staff states the design for emergency power for pressurizer heaters is consistent with NRC positions and is acceptable.
The PORVs themselves are air operated with DC control solenoids.
Power for the solenoid valves is supplied from the 125 VDC Vital Instrumentation and control power system. This power system receives power from station batteries as described in FSAR section 8.3.2.1.4 to provide uninterrupted power for safety related control and instrumentation circuits.
The batteries receive charge from the 60 0 VAC Essential Auxiliary Power System which receive blackout power as previously described. The battery is capable of one hour of operation without additional charging as discussed in the FSAR.
The NRC has also reviewed McGuire's design for emergency power for the PORVs and the PORV block valves.
As documented in the SER for McGuire, Supplement 4, the NRC staff has found the design to be consistent with NRC positions and is acceptable.
As each of the components governed by the affected specification are permanently connected to emergency power sources, the surveillance requirement is not needed and deleting it is an administrative matter.
Analysis of Significant Hazards Considerations Pursuant to 10CFR 50.91, this analysis provides assurance that the proposed changes to the McGuire Nuclear Station Technical Specifications do not involve any significant hazards considerations as defined by 10CFR 50.92.
(1) The proposed changes would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The deletion of channel checks for RWST level and the RVLIS lower range do not impact instrument operability and do not affect any accident sequences.
These instruments are used following an accident to mitigate the consequences of an accident.
As these instruments only monitor parameters, there can be no affect upon the probability of an accident.
The operability of these instruments is not affected by the deletion of the channel checks as previously discussed.
As the operability of these instruments is not compromised, any action taken based upon displayed data will thus be unchanged by the deletion of these surveillance requirements, thus the consequences of an accident are unaffected.
The proposed change to delete the analog channel operational test for the flow rate measurement device in the waste liquid effluent line is administrative as none of the functions checked by an ACOT exist for this device. The line serves to discharge liquid effluent and has no impact upon any accident sequence.
The deletion of the surveillance requirement for the PORVs, PORV block valve, ard the pressurizer heaters is also an administrative matter. As previoud y discussed, these components are permanently connected to essential pwer which is powered by the diesel generators in the event of a station blackout.
The function of these components is unaff ected by the deletion of the surveillance requirement, thus the probability or i
consequences of any accident are not affected.
(2) The proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed deletions of the various surveillance requirements cannot create the possibility of a new or different kind of accident form any accident previously evaluated.
The deletion ' of the channel checks and the ACOT will not allow any hardware changes cr loss of safety function.
The' instruments have proven to be reliable such that other surveillance are sufficient to ensure instrument operability.
The deletion of requirements relative to the emergency power sources for the PORVs, block valves, and pressurizer heaters will not impact or create any accident scenarios as these components are permanently connected to essential power sources; thus these surveillances serve no purpose.
(3) The proposed changes would not involve a significant reduction in a margin of safety.
The deletion of the subject surveillance requirements will not affect any margin of safety.
The other required surveillance requirements are sufficient to ensure equipment operability as previously discussed.
As equipment operability is unaffected by the proposed changes, no margin of safety is affected.
Based upon the preceding analysis, Duke Power Concludes the proposed changes do not involve any significant hazards considerations as defined by 10CFR 50.92.
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