ML20236L653

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Responds to 950330 TIA 95-002 Requesting NRR Review Design & Licensing Basis for TS 3.2 Re Operability of CVCS at Plant Unit 2.Since Charging Pumps Do Not Perform Any ECCS Function Pumps Not Required to Be Powered from Normal & EP Sources
ML20236L653
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 07/07/1995
From: Calvo J
NRC (Affiliation Not Assigned)
To: Matthews D
NRC (Affiliation Not Assigned)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 TAC-M92012, NUDOCS 9807130112
Download: ML20236L653 (3)


Text

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. ATTACm!DT n

    • "'4 4g a* *t UNITED STATES i

j NUCLEAR REGULATORY COMMISSION WASHINGTON. 0.C. 30eeHoot J

k * . .l . ,/ July 7, 1995 l

MEMORANDUM TO: David B. Matthews, Project Director Project Directorate !!-l Division of Reactor Projects 1/11 Office of Nuclear Reactor Regulation .

FROM: Jose A. Calvo, Chief Electrical Engineering Branch * ' (* '

Division of Engineering Office of Nuclear Reactor Regulation

SUBJECT:

REQUEST FOR TECHNICAL ASSISTANCE - EVALUATION OF H. B. ROBINSON UNIT 2 POSITION PERTAINING TO TECHNICAL SPECIFICATION COMPLIANCE AND OPERABILITY OF CHEMICAL AND VOLUME CONTROL SYSTEM (TAC NO. M92012)

In Task Interface Agreement 95-002 sent to J. A. Zwolinskt on March 30, 1995 E. W. Herschoff (Region 11) requested that NRR review the design and licensing basis for the chemical and volume control system (CVCS) charging pumps and interpret Technical Specification (TS) 3.2 regarding the operability of the CVCS at H. B. Robinson Steam Electric Plant Unit 2 (HBR2).

TS 3.2.2 requires, in part, that the reactor not be made critical unless two charging pumps are operable. Operability (i.e., of the CVCS charging pumps) is defined in TS Definition 1.3 as follows:

A system, subsystem, train, component or device shall be operable or have operability when it is capable of performing its spectfled function (s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emeroency electrical power sources, cooling or seal water, lubrication or other auxtllary equipment that are required for the system, subsystem, train, component or device to perform its specified function (s) are also capable of performing their related support function (s).

Of the three positive displacement charging pumps (A, B, and C) installed at HBR2 for the CVCS function, only two (B and C) have normal (offsite power) and emergency (emergency diesel generators) electrical power sources; the A charging pump is powered from only the normal electrical power source.

CONTACT: P. Kang. EELB/DE 415-2779 9807130112 980624 ER -155 PDR

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, David B. Matthews The licensee has been regularly removing either 8 or C charging pumps from service for routine maintenance / surveillance and has been regarding the A charging pump as a fully operable replacement for either the 8 or C pump removed from service. Because the resident inspector believed that the Itcensee's A pump replacement activity violated the TS, he asked the licenses to explain its position.

In response to the inspector's concern, the licensee reviewed the original CVCS design and found that the CVCS charging pumps at HBR2 are neither designed to perform any emergency core cooling system (ECCS) functions nor given any credit in the accident analyses. Although two power sources (normal and emergency) happen to be available for two of the three charging pumps, they are designed to be run by the normal power source only. One charging pump is adequate for normal CVCS makeup function of the reactor coolant system, and the use of any two pumps (i.e., considering a single failure) of the three charging pumps meets TS 3.2.2 for making the reactor critical. The Itcensee took a position that this was consistent with its original CVCS design and its current Ilcensing basis, thus satisfying TS 3.2 for CVCS operability at HBR2.

To ascertain the validity of the Itcensee's position, Region !! requested that NRR interpret TS 3.2 regarding CVCS operability.

The staff reviewed the Westinghouse plant design and licensing basis for its charging pump. It found that one of the design function of the CVCS is to maintain the proper water inventory in the reactor coolant system. Because of this function, a small-break loss-of-coolant accident can be accommodated by the charging pumps. In fact, In Westinghouse design two of the three charging pumps in ing plants are designed to serve as high head injection pumps during accident conditions. For those plants at which the ECCS function is performed, two of the three CVCS charging pumps are required to be on the safety buses that are powered from both normal and emergency power sources, while the third pump is powered from only the normal power source.

The staff reviewed the licensing and design basis for HBR2's ECCS and CVCS regarding the use of the charging pumps in the updated final safety analysis report (FSAR). It also reviewed the accident analyses in Chapter 15 of the updated FSAR for the plant systems and components required for pitigating accidents. During this review, the staff found that the ECCS function at HBR2 ts performed by three passive cold leg accumulators, three safety injection (high head) pumps, and two residual heat removal (low head) pumps. Thus, the CVCS charging pumps are neither used for~ accident mitigation nor given any +

credit in the accident analysis for HBR2.

Based on the above, the staff concludes that since the charging pumps at HBR2 do not perform any ECCS function, they are not required to be powered from normal as well as emergency power sources. Therefore, only normal power is

! sufficient for these pumps to meet their operability requirements.

(

David B. Matthews l On June 3, 1995, the licensee submitted a TS amendment to clarify HBR2 TS 3.2 regarding the charging pumps and their operability.

l Docket No.: 50-261 l

l I

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