ML20206U104

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Proposed Tech Specs Section 4.4.6.2.2.e,deleting Reference to ASME Code Paragraph IWV-3472(b) Re Frequency of Leakage Rate Testing for Valves Six Inches Nominal Pipe Size & Larger
ML20206U104
Person / Time
Site: Millstone Dominion icon.png
Issue date: 05/17/1999
From:
NORTHEAST NUCLEAR ENERGY CO.
To:
Shared Package
ML20206U103 List:
References
NUDOCS 9905250048
Download: ML20206U104 (10)


Text

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a 347 5 2/19/97 REACTOR c00LANT 5YSTDI 15 day g

j DPERATIONAL LEAKAGE SURVEILLANCE REQUIREMENTS 4.4.6.2.1 Reactor Coolant S each of the above limits by:ystem leakages shall be demonstrated to be within a.

Monitoring the containment atmosphere (gaseous or particulate) radioactivity monitor at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; b.

Monitoring the containment drain sump inventory and discharge at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; Measurement of the CONTROLLED LEAXAGE to the reactor coolant pump c.

seals when the Reactor Coolant System pressure is 2250 1 20 least once per 31 days with the modulating valve' fully open. psia at The MODE 3 or 4; provisions of Specification 4.0.4 are not applicable for entry into 1

d.

Performance of a Reactor Coolant System water inventory balance at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; and Monitoring the Reactor Head Flange Leakoff System at least once per e.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

4.4.6.2.2 Table 3.4-1 shall be demonstrated OPERABLE by verifying lea its limit:

At least once each REFUELING INTERVAL,

-a.

[

b.

Prior to entering MODE 2 whenever the plant has been in COLD SHUTDOWN for 7 days or more and if leakage testing has not been performed in the previous g months, Prior to returning the valve to service following maintenance, c.

repair or replacement work on the valve',

d.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual W

(c.3 4

e.

e.

...........................,,........,,,......,...... m,. m.

e y

The provisions of Specification 4.0.4 are not applicable for entry into MODE 3 cr 4.

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MILLSTONE UNIT 3 osaa 3/4 4-23 Amendment No. J99.133

0 Docket No. 50-423 B17764 i

Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specification 1

Reactor Coolant System Operational Leakage (TSCR 3-29-98)

Retyped Pages May 1999 h i.m

...a

.n s

t Nucisar Rngulatory Commission B17764/ Attachment 2/Page 1 RETYPE OF PROPOSED REVISION Refer to the attached retype of the proposed revision to the Technical Specifications (TS). The attached retype reflects the incorporation of the proposed changes to the TS.

Pending Technical Specification revisions are not reflected in the enclosed retype. The enclosed retype should be checked for continuity with recently issued TS prior to issuance.

l

-REhCTORCOOLANTSYSTEN OPERATIONAL LEAKAGE SURVEILLANCE REQUIRENENTS 4.4.6.2.1 Reactor Coolant System leakages shall be demonstrated to be within f each of the above limits by:

a.

' Monitoring the containment atmosphere (gaseous or particulate) radioactivity monitor at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; b.

Monitoring the containment drain sump inventory and discharge at I

least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; Measurement of the CONTROLLED LEAKAGE to the reactor coolant pump c.

seals when the Reactor Coolant System pressure is 2250 i 20 least once per 31 days with the modulating valve fully open. psia at The provisions.of Specification 4.0.4 are not applicable for entry into MODE 3 or 4; d.

Performance of a Reactor Coolant System water inventory balance at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; and Monitoring the Reactor Head Flange Leakoff System at least once per e.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

4.4.6.2.2 Each Reactor Coolant System Pressure Isolation Valve specified in Table 3.4-1 shall be demonstrated OPERABLE by verifying leakage to be within its limit:

At least once each REFUELING INTERVAL, a..

b.

Prior to entering N0DE 2 whenever the plant has been in COLD SHUTDOWN for 7 days or more and if leakage testing has not been performed in the previous 9 months, Prior to returning the valve to service following maintenance, c.

repair or replacement work on the valve, d.

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />' following valve actuation due to automatic or manual action or flow through the valve, and When tested pursuant to Specification 4.0.5.

l e..

The provisions of Specification 4.0.4 are not applicable for entry into MODE 3 or 4.

NILLSTONE - UNIT 3-3/4 4-23 Amendment No. 199, J77, i

os44

Docket No. 50-423 B17764 i

Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specification Reactor Coolant System Operational Leakage (TSCR 3-29-98)

Background and Safety Summary i

i May 1999

i Nuclear Rtgul: tory Commission B17764/ Attachment 3/Page 1 Backaround in accordance with the requirements of 10CFR50.55a(f)(4)(ii) inservice Testing (IST) programs are required to be updated every 10 years to the edition of the ASME Code endorsed by the NRC 12 months prior to the start of the next 120 month interval. The MP-3 IST Program second 10 year interval began in February 1998. In this regard the MP-3 program is compliant with the 1989 edition of the Code. During a review of the TS a discrepancy between the revised IST program requirements and Technical Specification 4.4.6.2.2.e was self identified. TS section 4.4.6.2.2.e references ASME Code paragraph IWV 3427(b) which is included in the 1983 Edition of the Code and was employed during the first ten year interval. The provisions of IWV 3427(b) requires trending for 6 inch and larger valves and increased frequency of valve leakage testing based upon increasing leakage trends. However this requirement was eliminated from the Code as it was not deemed to provide a worthwhile benefit based upon industry i

experience. As such the requirements of IWV 3427(b) were not carried forward and included in the 1989 Edition of the Code.

l i

The Technical Specifications need to be revised to align the test requirements with the current IST Program requirements and industry practices. With respect to the above reference to IWV 3427(b) as presented in TS 4.6.6.2.2.e is deleted. Surveillance

)

requirements for valve leakage tests will be accomplished pursuant to the provisions of TS 4.0.5 as presented in this PTSCR. As such this TS is revised to align with test requirements as presented in the current MP-3 IST program.

Safety Summary This PTSCR revises TS section 4.4.6.2.2.e such that reference to ASME Code paragraph IWV-3472(b) which pertains to frequency of leakage rate testing for valves 6 inches nominal pipe size and larger is deleted. TS 4.4.6.2.2.e is revised to indicate that the surveillance interval and frequency of surveillance leakage rate testing for these valves will be performed pursuant to the requirements of TS 4.0.5 and the MP-3 IST program.

The elimination of the IWV requirement and specifying that testing be performed in accordance with the IST Program results in TS which are more consistent with the testing requirements specified in Westinghouse Owr.ers Group (WOG) Standard Technical Specification (STS) for Pressure isolation Valves (PlVs). This PTSCR change will not affect the ability of a PlV to perform its required Reactor Coolant System (RCS) pressure isolation safety function of limiting RCS leakage to prevent overpressure failure of attached low pressure systems.

4 Nucl:ar R gulatory Commission B17764/ Attachment 3/Page 2 -

- This proposed TS change does not alter or affect the design, operation, maintenance or surveillance associated with MP-3 Structures, Systems, and Components in a detrimental manner during normal or accident operations.

This proposed change is considered safe because it will not result in the plant being operated in an unsafe condition, decrease available safety margins, operate outside of design bases parameters, nor adversely impact the consequences of an accident. It will cause no increase in risk to the public health or safety. It does not increase either the probability of event occurrence, the probability of human errors mitigating the event, the probability of the failure of mitigating equipment, nor does it introduce any new accidents or equipment malfunctions.

The proposed TS changes are considered safe and do not represent an Unreviewed Safety Question.

l

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5 Docket No. 50-423 B17764 Millstone Nuclear Power Station, Unit No. 3 Reactor Coolant System Operational Leakage (TSCR 3-29-98)

Significant Hazards Consideration and Environmental Considerations May 1999

Nucirr Regulatory Commission B17764/ Attachment 4/Page 1 Sianificant Hazards Consideration Northeast Nuclear Energy Company (NNECO) has reviewed the proposed revision in accordance with 10 CFR 50.92 and has concluded that the revision does not involve any Significant Hazards Considerations (SHC). The basis for this conclusion is that the three criteria of 10 CFR 50.92(c) are not satisfied.

The proposed Technical Specification revision does not involve a SHC because the revision would not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change revises Technical Specification surveillance requirement 4.4.6.2.2.e to eliminate reference to ASME Code paragraph IWV-3427(b) and state instead to perform testing pursuant to TS 4.0.5.

Compliance with IWV-3427(b) imposes trending requirements and tracking of increased frequency test i

requirements on Reactor Coolant System PlVs 6 inches or greater nominal size.

The latest endorsed Edition of ASME Section XI (1989 Edition) requires the use of ASME/ ANSI OM-1987 including the OMa-1988 Addenda. However there is no similar paragraph in the current ASME/ ANSI OM Code with requirements such as those contained in IWV 3427(b). The IWV-3427(b) requirements were eliminated when transferred from the ASME B&PV Code Section IWV, to ASME/ ANSI Code OM-1987 (OM-10).

The test conditions for PlV leakage testing are unchanged and represent analyzed configurations. This change eliminates an unnecessary test requirement and incorporates Westinghouse Owner's Group (WOG)

Standard Technical Specifications (STS) frequency requirements which are deemed to "..substantially reduce the probability of an intersystem LOCA." This change in testing frequency requirements does not affect the accident mitigation capabilities of the RCS PlVs.

This change is bounded by existing accident analysis.

Therefore, it is concluded that, with no effect on accident mitigation, the proposed revision does not involve a significant Mcrease in the probability or consequences of an accident previously evaluated F 3e to the public is unchanged).

2.

Create.the possibility of a new or different kind of accident from any accident previously evaluated.

Eliminating the IWV-3427(b) trending for 6 inch and larger valves (and the accompanying increased frequency testing requirement) will not effectively change actual testing frequencies since the frequencies are eclipsed by the remaining Technical Specification requirements. Specifying testing in accordance with the IST Program makes the Technical Specifications more consistent with testing requirements specified in Westinghouse Owners Group STS for PlVs. This change

Nucl:nr Regulatory Commission B17764%ttachment 4\\Page 2 will not affect the ability of a PlV to perform its required RCS pressure isolation safety function of limiting RCS leahage to prevent overpressure failure of attached low pressure systems.

The frequency of testing or the testing itself are not initiating events to postu tod accidents. Therefore, no different accidents than previously evaluated are created by this change.

Thus, the proposed revision does not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Involve a significant reduction in the margin of safety.

There is no impact on the Margin of Safety as defined in the Basis of any Technical Specification. Periodic surveillances provide continued assurance in the capability of safety related equipment to perform its design safety (accident mitigating) function. Per the Westinghouse Owners Group STS, periodic leakage testing of Reactor Coolant System PlV's substantially reduces the probability of intersystem LOCAs. This change brings the required level of surveillance testing into closer compliance with the STS.

The proposed Technical Specification change does not affect the four " Defense-in-Depth" protecbve boundaries of fuel matrix and fuel cladding, RCS pressure boundary, Containment and site radiological limits. This TS change presents no reduction in the margin of safety pertaining to the fuel, RCS or Containment. The lack of an effect on the probability and consequences of accident occurrence, as discussed in the previous paragraphs, ensures a high degree of confidence with respect to protecting the public health and safety.

1 In conclusion, based on the information provided, it is determined that the proposed 1

revision does not involve a SHC.

Environmental Coasiderations NNECO has reviewed the poposed license amendment against the ciiteria of 10CFR51.22 for environmental considerations. The proposed revision does not involve a SHC, does not signi'icantly increase the type and amounts of effluents that may be released offsite, does not significantly increase individual or cumulative occupational rari!ation exposure. Based on the foregoing, NNECO concludes that the proposed revision meets the criteria delineated in 10CFR51.22(c)(9) for categorical exclusion from the requirements for environmental review.