ML20211P581
| ML20211P581 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/16/1997 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20211P584 | List: |
| References | |
| NUDOCS 9710210029 | |
| Download: ML20211P581 (7) | |
Text
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,1 Dave Mitey 5:uthera Nuclear 3
,, We President Operang Company f arley Prc/ct PO. 00s 1295 Dirmingham, Alatama 35201 Tel 205.992.5131 October 16, 1997 SOUTHERN COMPANY Energy to Serve YourWorld" Docket Numbers: 50-348 10 CFR 50.90 50-364 U.S. Nuclear Regulatory Commission >
A~ITN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Request For Technical Specification Changes Chareine Pump-Shutdown Ladies and Gentlemen:
In accordance with the provisions of 10 CFR 50.90, Southem Nuclear Operating Company (SNC) proposes to amend the Farky Nuclear Plant (FNP) Unit I ano Unit 2 Techni-al Specifications (TS),
Appendix A to Operating Licenses NPF-2 and NPF-8. This TS amendment request revises the number of allowable charging pumps capable ofinjecting in the Reactor Coolant System (RCS) when the temperature of one or more of the RCS cold leg temperatures is less than 180"F.
The number of operable charging pumps is limited, when RCS cold leg temperature is 18U"F or less, to prevent simultaneous injection by two or more charging pumps. This limits the magnitude of a mass injection event. The proposed amendment will modify TS 3.1.2.3 to allow a maximum of two charging pumps to be capable ofinjection into the RCS during charging pump swap operations. In addition, an action statement to address more than one OPERABLE charging pump will be provided. He current LCO does not provide an action for this condition. This amendment also changes TS BASES section 3/4.1.2 to address the changes to TS 3.1.2.3. Clarification on allowable plant conditions during the pump swap
- evolution are added.
Enclosure i provides a basis for the proposed changes. Enclosure 2 provides the basis for a determination that the proposed changes do not involve significant hazards considerations pursuant to 10 CFR 50.92.
Enclosure 3 provides the proposed changes to the Unit 1 TS Enclosure 4 provides the proposed changes to the Unit 2 TS Enclosure 5 provides the Units 1 and 2 marked-up TS pages. Please note that the Unit 2 marked-up TS pages reflect amendments 118 and 120 that Nuclear Regulatory Commission approved but are yet to be implemented.
SNC has determined that the proposed changes will not significantly affect the quality of the human emironment.. A copy of the proposed changes has been sent to Dr. D. E. Williamson, the Alabama State Designee, in accoidance with 10 CFR 50.91(b)(i). /
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4 4 U.S. Nuclear Regulatory Commission Page 2 SNC requests that the NRC r ,iew and approve the proposed TS changes prior to the next scheduled Unit 2 refueling outage beginning in March 1998. SNC plans to imple.nent the proposed change within 30 days ofissuance by the NRC.
Mr. D. N. Morey states that he is a vice president of SNC, and is authorized to execute this oath on behalf of SNC and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true.
Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY ff )?14 W' Dave Morey Sworn to and subscribed before e thisk.Ya ..I997 nraAb(s ad Wvo(
' 1 Notary Public (/
My Commission Expires: M"->>I[fNf EWC:maf 0377rev2. doc
Enclosures:
- 1. Basis for the TS Change
- 2. 10 CFR 50.92 Evaluation
- 3. Unit 1 Technical Specification Pages
- 4. Unit 2 Technical Specification Pages
- 5. Units 1 and 2 Marked-Up Technical Specification Pages cc: Mr. L. A. Reyes, Region II Administrator Mr. J.1. Zimmerman, NRR Project Manager Mr T. M. Ross, Plant Sr. Resident inspector Dr. D. E. Williamson, State Department of Public Health
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Enclosure !
Joseph M. Farley Nuclear Plant Charging Pump - Shutdown Technical Specification Changes Basis for the TS Chance s
e
e Enclosure 1 Joseph M. Farley Nuclear Plant Charging Pump - Shutdown Technical Specification Changes Basis for the TS Chance Descrintion of Chances:
He proposed TS change increases the number of allowable operable charging pumps when the Reactor Coolant System (RCS) is less than 180'F. He proposed amendment will modify TS 3.1.2.3 to allow a maximum of two charging pumps to be capable ofinjection into the RCS during charging pump swap operations for a maximum of 15 minutes. In addition, an action statement to address having more than one charging pump capable ofinjection into the RCS is provided. He current LIMITING CONDITION FOR OPERATION does not provide an action for this condition. His amendment also changes TS BASES section 3/4.1.2 to address the changes to TS 3.1.2.3. Clarification on allowable plant conditions while the pump swap evolution is being conducted are added to the bases.
General Discussion:
TS 3.1.2.3 prohibits more than one charging pump from being OPERABLE when one or more of the RCS cold leg temperatures is less than 180*F. SR 4.1.2.3.2. defines that the means of determining thct a charging pump is " inoperable" is by verifying that the associated circuit breakers be removed from their electrical supply circuits. These requirements have the effect of rendering only one charging pump capable ofinjecting into the RC3 when the RCS is at a temperature less than 180*F. Rcre is no provision to allow for maintaining charging flow during pump swap operations. Here is no action statement in TS 3.1.2.3 to address having two charging pumps capable ofinjecting into the RCS.
In order to maintain a steady supply of filtered seal water to the Reactor Coolant Pump (RCP) number one seals while swapping the on service charging pump, it is necessary to momentarily have two charging pumps running. TS 3.1.2.3 currently does not allow this option since it allows only one charging pump motor circuit breaker to be installed in the electrical supply circuit. This restriction prevents a mass addition transient that could potentially exceed the capacity of one Residual Heat Removal (RHR) relief valve, thus, resulting in exceeding RCS pressure limits. The proposed bases change clarifies that the RCS be in a non water solid cond; tion and two RHR relief valves be operable or that the RCS be vented while the pump swap evolution is in progress.
Charging pump swaps are needed to accommodate routine operational evolutions such as surveillance testing and maintenance. It is conunon operational practice '.a keep seal injection to the RCP number one seal when RCS water level is above the level of the seal package. This practice prevents unfiltered RCS water from entering the seal and contributing to their degradation by depositing particles on the seal faces that may result in premature wear. Swaps that involve stopping the operable charging pump for a period before starting the replacement pump may result in degradation of the seat. The loss of supply pressure to the seal will allow it to move to the fully lowered position. Upon the subsequent charging pump restart the seal may not properly retum to the nonnal position resulting in a " cocked" seal. The proposed change to specification 3.1.2.3 allows two charging pump ; to be capable of injection into the RCS for a period of 15 minutes or less to facilitate on service pump swaps.
The proposed changes are consistent with NUREn 1431, Standard Technical Specifications Westinghouse Plants.
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. , s Enclosure 2 Joseph M. Farley Nuclear Plant Charging Pump - Shutdown Technical Specification Changes 10 CFR 50.92 Evaluation
e Enclosure 2
. . Joseph M. Farley Nuclear Plant Charging Pump - Shutdown Technical Specification Changes 10 CFR 50.92 Evaluation Pursuant to 10 CFR 50.92, SNC has evaluated the proposed amendments and has determined that operation of the facility in accordance with the proposed amendments would not involve a significant hazards consideration. He basis for this determination is as follows:
- 1. De proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes to TS 3.1.2.3 allow two charging pumps to be capable ofinjecting into the reactor coolant system (RCS) for a period not to exceed 15 minutes while RCS cold leg temperature is at or below 180'F. The intent is to allow the operator to start a second pump long enough to ensure that it operate properly and then to promptly secure the pump that was originally running. His order of pump operation will allow seal injection flow to be maintained to the RCS pumps number one seal continuously, thus preventing loss of pressure to the seals and maintaining filtered water flow through the seals. The proposed revised bases address the potential for a RCS mass addition transient.
Guidance is given to prevent the charging pump swap from being conducted while the RCS is in a condition conducive to an overpressure transient. The RCS should be in a non water solid condition and the residual heat removal (RHR) relief valves must be operable or the RCS must be vented while the pump swap evolution is in progress. The proposed revision to TS 3.1.2.3 allows 15 minutes to have two pumps capable ofinjec'ing into the RCS, although two pumps will be running only momentarily, the remaining time is needed to perform the charging pump circuit breaker racking operations needed to render one of the two pumps incapable ofinjecting into the RCS. The proposed actions statement 3.1.2.3b. directs that immediate action be taken to render all but one pump inoperable should the allotted 15 minutes be exceeded. This action is more appropriate than is currently specified.
These proposed changes include sufficient controls to prevent an RCS overpressurization event.
Thercfore, the proposed TS changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
This proposed change involves no change to the physical plant. It allows for a very limited and controlled operational change. The change increases the potential for a mass addition transient while the RCS is below 180 F; however, sufficient controls are proposed to prevent a cold overpressure event.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
Enclosure 2 10CFR50.92 Evaluation
- 3. He proposed changes do not involve a significant reduction in a margin of safety.
He proposed change includes controls sufficient to prevent a significant reduction in the possibihty or consequences of an accident. The proposed change specifies that the pump swap evolution be perfonned under conditions that will prevent an adverse plant transient. In addition, the proposed revision provides appropriate operator action that does not currently exist. This change is consistent with NUREG 1431, Standard Technical Specifications Westinghouse Plants.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Conclusion Based on the preceding analysis, SNC has determined that the proposed changes to the Technical Specifications will not significantly increase the probability ( r consequences of an accident previously evaluated, create the possibility of a new or different kind of awident from any accident previously evaluated, or involve a significant reduction in a margin of safety. SNC therefore concludes that the proposed changes meet the requirements of 10 CFR 50.92(c) and do not involve a significant hazards consideration,
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