ML20236L563
Text
_ - - _ _ _ _ _ _ _ _ - - - - - _ - - - - _ - - - - - - _ - - _ _. - - _ - - - - - - - - - - - - - - - - - - - _ _ - - -
?
August 10, 1994 o*
Docket No. 50-397 MEMORANDUM FOR:
A. Bill Beach, Director Division of Reactor Safety and Projects Region IV FROM:
Elinor G. Adensam, Assistant Director for Region IV Reactors Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation
SUBJECT:
RESPONSE TO TASK INTERFACE AGREEMENT (93-TIA-012) - WNP-2 TESTING OF SUPPRESSION POOL COOLING MODE OF RESIDUAL HEAT REMOVAL (RHR) EMERGENCY OPERATING PROCEDURES (EOPs)
This responds to the former Region V's request dated April 22, 1993, for NRR's evaluation of the WPPSS (the Supply System) practices associated with testing the RHR system while aligned in the suppression pool cooling mode (SPCM). Our evaluation is provided in the enclosure. NRR determined that the Supply System practice does not conform to a literal reading of the technical specifications.
If you have any questions, please contact the Project Manager, Jim Clifford, at (301) 504-1352. This completes NRR action on TAC No. M86685.
Original Signed By Elinor G. Adensam, Assistant Director I
for Region IV Reactors Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation
Enclosure:
DISTRIBUTION NRR Assessment of WNP-2 E0P Docket File Deviations PDIV-2 Reading SVarga cc w/ enclosure:
JRoe R. Cooper, RI EAdensam E. Merschoff, RII TQuay E. Greenman, RIII DFoster-Curseen K. Perkins, RIV/WCFO JClifford tRGiardina RBarr, SRI /WNP-2 OFC LA:DRPW f/[. 6 PM:PDIV-J D:PDIV-2 _
ADSfd NAME DFoster-Curseen JClifdrd:pk TQuayY EAderkam i
DATE [/[94
//I/94 if/$/94
[//0/94 0FFICIAL RECORD COPY DOCUMENT NAME: WNP86685.TIA 9807130074 980624
~
h
-155 PDR
~.
s j
i l
E0Ps, and operating procedures were not changed. The RI also questioned the validity of the licensec's calculations regarding determination of the minimum SPCM RHR flow rate required to meet the design-basis heat load.
Region V requested NRR sssistance to (1) detemine whether the licensee's implementation of their TS surveillance procedures violates TS 4.6.2.3.b., (2) determine if the WNP-2 RHR flow rate during SPCM meets the design-basis flow rate, and (3) determine if the licensee's implementation of this surveillance is consistent with that at other BWR facilities.
III. EVALUATION i
A.
Surveillance Test Methodology i
With regard to whether or not the licensee's surveillance procedure meets the TS requirement, OTSB has reviewed the material provided as well as the improved Standard Technical Specifications (STS) for BWRs (NUREG-1433 for BWR-( and NUREG-1434 for BWR-6). WNP-2 TS 4.6.2.3.b.
states that:
The suppression pool cooling mode of the RHR system shall be demonstrated OPERABLE:
b.
By verifying that each of the required RHR pumps develops a flow of at least 7450 gpm on recirculation flow through the RHR heat exchanger and the suppression pool when tested pursuant to 4.0.5.
- The determination of whether or not a violation occurred depends on the definitions in the context of RHR system design of recirculation flow and SPCM of operation.
In a general sense, recirculation flow means that a system is aligned such that the liquid is taken from a source, pumped through the system, and returned to the source. Based on the RHR system drawing and the procedure alignment described above, either alignment allowed by the procedure would meet,the recirculation flow requirement. Thus based just on this general approach, no violation would be considered to have occurred. However, the second portion of the TS that calls for SPCM of operation in conjunction with recirculation flow determines system operability. The LC0 portion of TS 3.6.2.3 and Surveillance Requirement 4.6.2.3.a. do not specifically define the system alignment for this mode of operation, nor do the bases or the improved STS LCO and associated bases explicitly describe the system alignment. The FSAR does describe the RHR system alignment for SPCM of operation. FSAR Section 6.2.2.2., through FSAR Amendment 44, states, "(t)he rated containment cooling flow, 7450 gpm, can be achieved through the LPCI [ low-pressure coolant injection) line, the drywell spray line, or through the test line which directs the heat exchanger l
discharge directly into the suppression pool." In addition FSAR Section 7.3.1.1.5.b., "SPCM Operation," explicitly describes RHR system I
e
)
3-v alignment for SPCM of operation for both nonnal and LOCA conditions.
In both cases the test return line through valve RHR-V-24 is the means of recirculation flow that was the plant's licensing basis. The suppression pool spray valve (RHR-V-278) and spray lines are not described. Also, the E0Ps and the plant procedure for RHR system operation use the FSAR description for SPCM alignment.
In order to meet both the SPCM of operation and recirculation flow requirements of TS 4.6.2.3.b., the RHR system needs to be aligned as described in the FSAR, the E0Ps, and the plant procedure on RHR system operation. The plant procedure that allows the opening of valve RHR-V-I 278 to assure adequate flow for surveillance purposes does not meet this l
dual requirement of the plant licensing basis, and therefore, the licensee did not comply with its TS.
B.
Adequacy of Observed SPCM Flow Rate Regarding Region V's second request, OTSB and SRXB do not believe it is appropriate at this time to review the calculation indicating that a lower SPCM RHR flow rate might be acceptable. A staff review of the calculation would not provide justification that the system alignment was in accordance with the TS and the plant licensing basis.
It wauld only determine whether or not the flow rate (7450 gpm) specified in the surveillance requirement (TS 4.6.2.3.b.) could be changed to a lower value. We recommend that, if appropriate, the licensee submit the calculations along with a TS amendment request to change the flow requirements for the SPCM of operation for staff review.
C.
Consistency of Test Methodology In order to definitively respond to this request, it would be necessary to determine how each BWR facility demonstrates that it meets its SPCM design basis as described in each facility's FSAR. This would require generation of a generic request for information which would require OMB clearance and authorization. NRR does not believe sufficient justification exists in this case to warrant such a request.
IV.
CONCLUSION The NRR staff concludes that the licensee's surveillance test of the RHR pump in the SPCM did not meet the applicable TS requirement.
In addition, NRR believes it is appropriate to review calculations regarding minimum required SPCM fbw only in conjunction with an associated TS amendment request. Finally, NRR believes it is impractical and unwarranted to actively seek out practices at all BWRs relative to SPCM testing.
Principal Contributor:
R. Giardina Date: August 10, 1994
__