ML20205F118

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Proposed Tech Spec Change Request 147,extending Two 18-month Surveillances Required in Mode 6,HPI & LPI Pump & Valve Testing & Permanent Extension to Surveillances for Reactor Vessel Internal Vent Valves
ML20205F118
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 08/14/1986
From:
FLORIDA POWER CORP.
To:
Shared Package
ML20205F115 List:
References
NUDOCS 8608190093
Download: ML20205F118 (6)


Text

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REACTOR C00IANT SYSTEN

. SURVEILLANCE REQUIREMENTS (Continued)

b. Each internals vent valve shall be demonstrated OPERABLE at least -

once per fuel cycle, by: l

1. Verifying through visual inspection that the valve body and valve disc exhibit no abnormal degradation.
2. Verifying the valve is not stuck in an open position, and
3. Verifying through manual actuation that the valve is fully open with a force of 1425 lbs (applied vertically upward).

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l CRYSTAL RIVER - UNIT 3 3/4 4-32 Amendment No. r

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REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS (Continued)

--. b. Each internals vent valve shall be demonstrated OPERABLE at-1 u r , by :

le,ast once per 3 - ' "f.tet eyele. , -_ -

1. Verifying through visual inspection that the valve body and valve disc exhibit no abnormal degradation,
2. Verifying the valve is not stuck in an open position, and L' 3. Verifying through manual actuation that the valve is fully open with a force of < 425 lbs (applied vertically upward) . -

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CRYSTAL RIVER - UNIT 3 3/4 4-32 Amendment No.

l FLORIDA POWER CORPORATION

. CRYSTAL RIVER UNIT 3 Docket No. 50-302/ License No. DPR-72 Request No. 147B High Pressure Injection and Low Pressure Injection Pump and Valwe Testing LICENSE DOCUMENT INVOLVED: Technical Specifications PORTIONS: 4.5.2.f DESCRIPTION OF REQUEST:

This submittal requests the surveillance interval in Technical Specification 4.5.2.f (High Pressure Injection [HPI] and Low Pressure Injection [LPI] pump and valve actuation testing) be changed from "at least once per 18 months" to "at least once per fuel cycle" on a one time basis only. This change would be effective until Refuel VI (currently scheduled to begin in September 1987).

REASON FOR REQUEST:

Technical Specification 4.5.2.f, regarding the actuation of valves and startup of pumps in the HPI and LPI systems, required this testing be accomplished during shutdown. This requicement conflicted with a commitment that HPI discharge valves are closed and " racked out" below 280 F in order to provide low temperature overpressurization protection.

However, this commitment would not permit HPI actuation testing to be performed si n'.e the Reactor Coolant System (RCS) temperature is always below 280 F in Modes 4, 5, and 6. In order to resolve the low temperature overpressurization concerns, the NRC issued Amendment Number 79 (dated July 23, 1985) to the Crystal River Unit 3 Technical Specifications. The amendment required the HPI pumps and valves to be tested only during Mode

6. This was acceptable since low temperature overpressurization protection is assured because the RCS cannot be overpressurized when the reactor vessel head is removed.

Due to the recent forced reactor coolant pump (RCP) outage at CR-3, the surveillance for the HPI and LPI pumps and valves will be required to be performed prior to the end of the current fuel cycl e. This surveillance l could not be satisfied during the recent outage since this necessitates removal of the reactor vessel head. The reactor vessel head was not removed during the forced RCP outage. The surveillance for the HP1 and LPI pumps and valves is currently required to be completed by October 1986.

However, the fuel cycle is not scheduled to end until September 1987.

Florida Power Corporation (FPC) requests the change to this surveillance interval be granted to eliminate the necessity for a mid-cycle shutdown to perform this surveillance during Cycle 6. The change would also reduce the need for an unnecessary removal of the reactor vessel head. This will result in the reduction of unnecessary personnel radiation exposur,e invnived with this evolution as well as a reduction in the probability of a reactor vessel head drop.

SAFETY EVALUATION OF REQUEST:

The testing required by Technical Specification 4.5.2.f was successfully i completed during the startup from the forced RCP outage in manners which assured that low temperature overpressurization was not a concern. This <

testing could not be utilized to satisfy Technical Specification 4.5.2.f l since it was not performed in Mcde 6 as required. However, the testing has successfully demonstrated the actuation of valves and automatic si.artup of pumps in the HPI and LPI systems.

Additionally, discussions with the NRC staff have indicated the 18 month surveillance interval was chosen so the testing could be performed during regularly scheduled refueling outages. There was no intent to force a shutdown for the sole purpose of performing this surveillance.

SHOLLY EVALUATION OF REQUEST:

FPC proposes this amendment does not involve a significant hazards consideration. The change of the surveillance interval for HPI and LPI pump and valve actuation testing from "at least once per 18 months" to "at least once per fuel cycle" is considered administrative in nature since it merely revises the surveillance interval to reflect the originally intended surveillance interval. Additional support for this consideration is provided by the fact testing required by the surveillance has been satisfactorily performed during the specified interval.

Based on the above, FPC finds the amendment will not:

1. Involve a significant increase in the probability or consequence of an accident previously evaluated because the testing required by the surveillance has been satisfactorily performed during the specified interval.
2. Create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed change introduces no new mode of pl ant operation nor does it require physical modification.
3. Involve a significant reduction in the margin of safety. Any reduction in the margin of safety will be insignificant since the purpose of this change is to conform with the originally intended surveillance interval.

ENERGENCY CORE COOLING SYSTDIS SURVEILLANCE REQUIRDIENTS (Continued)

2. Verifying the correct position of each mechanical position stop for each of the stop check valves listed in Specification 4.5.2.c.
3. Verifying that the flow controllers for the throttle valves listed in Specification 4.5.2.d operate properly.
4. A visual inspection of the containment emergency sump which verifies that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.
5. Verifying a total leak rate less than or equal to 6 gallons per hour for the LpI system at:

a) Normal operating pressure or a hydrostatic test pressure of greater than or equal to 150 psig for those parts of the system downstream of the pump suction isolation valve, and b) Greater than or equal to 55 psig for the piping from the containment emergency sump isolation valve to the pump suction isolation valve.

f. At least once per 18 months, in MODE 6, by
1. Verifying that each automatic valve in the flow path actuates to its correct position on a high pressure or low pressure g

safety injection test signal, as appropriate.3

2. Verifying that each HPI and LpI pump starts automatically upon receipt of a high pressure or low pressure safety injection i test signal, as appropriate.3 I
g. Following completion of HPI or LpI system modifications that could have altered system flow characteristics 1, by performance of a flow balance test during shutdown to confirm the following injection flow rates into the Reactor Coolant System:

HpI System - Sinale Pump 2 LpI System - Sinole pump Single pump flow rate greater than 1. Injection Leg A - 2800 or equal to 500 gpm at 600 psig. to 3100 gpm.

While injecting through 4 Injection 2. Injection Leg B - 2800 Legs, the flow rate for all to 3100 gpm.

combinations of 3 Injection Legs greater than or equal to 350 gpm at 600 psig.

I Flow balance tests performed prior to complete installation of modifications are valid if performed with the system change that could alt,r flow characteristics in effect.

2 The HPI Flow Balance Test shall be performed in MODE 3.

3 For Cycle VI, the surveillance frequency shall be at least once per fuel cycle in MODE 6.

CRYSTAL RIVER - UNIT 3 3/4 5-5 Amendment No.

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, EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 2.

Verifying the correct position of each mechanical position stop for each of the stop cneck valves listed in Specification 4.5.2.c. -

3. Verifying that the flow controllers for the throttle valves listed in Specification 4.5.2.d operate properly.

4.

A visual inspection of the containment emergency sump which verifies that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

5. Veritying a total leak rate less than or equal to 6 gallons per hour for the LP1 system at:

a)

Normal operating pressure or a hydrostatic test pressure of greater than or equal to 150 psig for those paru of the system downstream of the pump suction isolation valve, and b) Greater than or equal to 55 psig for the piping from the containment emergency sump isolation valve to the pump suction isolation valve.

i.

At least once per 18 months, in MODE 6, by l

O 1. Verifying that each automatic valve in the flow path actuates to its correct position on a hi signal, as appropriate.' gh pressure or low pressure safety injection test 2.

Verifying that each HP1 and LPl pump starts automatically upon receipt of a high pressure or low pressure safety injection test signal, as appropriate.3

g. Following completion of HP1 or LPI system modifications that could have altered system flow characteristics!, by performance of a flow balance test during shutdown to confirm the following injection flow rates into the Reactor Coolant System:

HPI Svstem - Sinrle Pumo2 LPI System - Single Pumo l

Single. pump flow rate greater than 1. Injection Leg A - 2800 to 3100 or equal to 500 gpm at 600 psig. gpm.

While injecting through 4 injation Legs, 2. Injection Leg B - 2800 to 3100 -

the flow rate for all combinations of 3 gpm.

Injection Legs greater than or equal to 350 gpm at 600 psig.

1 Flow balance tests performed prior to complete installation of modifications are valid if performed with the system change that could alter flow characteristics in effect.

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For C 3 ek TL h swn Llmu NA L begwm M k ew. pu k,i qcte in CRYSTAL RIVER - UNIT 3 3/4 3 3 Amendment No.

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