ML20247C261
| ML20247C261 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/01/1998 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20247C254 | List: |
| References | |
| NUDOCS 9805130072 | |
| Download: ML20247C261 (17) | |
Text
_______ __-_-_ _ _ _ _ _
'S ATTACHMENT 2 PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 TECHNICAL SPECIFICATIONS CHANGES Attached Pages Units 2 and 3 3.4-9 Bases 3.4-18 3.5-7 Bases 3.5-16 Bases 3.5-17 Inserts A and B (one copy) 1 1
I 1
9805130072 980501 DR ADOCK O 7
I l
SRVs and SVs 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR a'.l.3.1 Verify the safety function lift setpoints In accordance of the required SRVs and SVs are as with the follows:
Inservice Number of Setpoint SRVs fosial 4
1135 t 11.0 4
1145 1 11.0 3
1155 1 12.0 Number of Setpoint SVs (osio) 2 1260 13.0 SR 3.4.3.2
---------- ----NOTE
,d un ti l 12 Nou required be perfo ours a
er reacto steam pre ure and f1 are
- deouate to perform th test.
Verify each required SRV w e fii s o rc ~~#~
-~
24 months gmanually actuated (%c assensviemj
~
{
PBAPS UNIT 2 3.4-9 Amendment No.--210 0
4 BASES i
l SURVEILLANCE SR 3.4.3.2 1
REQUIREMENTS
.i (continued)
A manual actuation of e,ach required SEV is performeddo i
verify that, mechanically, the valve 'is functioning and no blockage exists in the valye discharge lin~e. properly can be demonstra This valves or bypass,tard by the respjmse of the tuebine control valves, by a/ change in the, measured ste flow, or by Jmy other method' suitable to verify steam f}
Adequate reactor steam done pressure must be availabljr'to {
perform)fiis test to ayo'id damaging ty valve. Alsp, or tufbine bypass valves to continue to contro i
[
prMsure when thr'SRVs divert st'eam flow upon/ opening.
gufficient time' is therefore.a'llowed after,tfie required M MM_ A pressure an& flow are achiev'ed to perforp'this test.
Adequate pressure at which this test iVto be perfo d is Systerminimum pressure set withgreater,than or equal to the il controllingfpressure (EHC/begins controlling pressur t a nominal 150 psig).
Addquate steam fYow is represan ed by at lea % 3 turbine
., bypass valves,open.
Plant st'artup is allowed prior to perfoming Jtfis test becay(e valve OPER%LITY and th setpointsf or overpressure protection f
te verified er ASME 4
Code requirements, pr r to valve in allation.
erefore this SR is modifie y a Note tha states the
- eillance, l
is not required be performed ntil 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />'after rea stfeampressure nd flow are a quatetoperformthete or i
dhe 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> lowed for manual kctuatiorvafter the
}
quired pressure i reached is sufficient to aSKieve stable,
' conditions for testing,atid provides Treasonable / time to /
/
1 complete the SR.
If
. the,f'ilure of the,so,ar valve failsfto actuate,due only to /
a lenoid but fs capable of' opening on'
! oye'rpressure, thysafety funct.i'on of the SRV is consid6 red j
APERABLE.
/
/
/-
,/
\\
i T)di 24 mo
. Frequency based on a need toA erform thef i
Aurveil nce under th condition that applyA ust prior 16
{
or du no a startuo rom a ola
'outaae.1 operating experience has show_n that these components will pass the SR l
when perfomed at the 24 month Frequency, which is based on the refueling outage.
Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES 1.
NEDC-32183P, " Power Rerate Safety Analysis Report for i
Peach Bottom 2 & 3," May 1993.
2.
UFSAR, Chapter 14.
PBAPS UNIT 2 B 3.4-18 Revisian No. 1#
L
ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
/-NOTE---/--------------
SR 3.5.1.12 required pd be perforpe'd until 12 No ours ter reactor steam pregure and f1 are
____Il_____________
Verify each ADS valve.
24 months actuated 1
6,f l
l PBAPS UNIT 2 3.5-7 Amendment No.
1
~
ECCS-Operating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.11 (continued)
REQUIREMENTS pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle.
was concluded to be acceptable from a reliabilityTherefore, the Fre standpoint.
This prevents an RPV pressure blowdown.This SR is modified SR 3.5.1.12
.A manual actuation of eacn 5 valve is p ormed to veri j that the e and solen d are functic ng properly a Ithat n ockage exis in the S/RV scharge lines.
is Jj is dpe'onstrated by e response of a turbine co 01 or ss valve or a change in e measured ste flow or by ny other met suitable to rify steam fl Adequate 5"Ed~ MfEd P 8 reactor ste pressure mus e available t perform this test to id damaging t valve. Also dequate steam f1 must b passing throu the main turb e or turbine byp s valv to continue control reac pressure when t ADS ves divert stjptm flow upon op ing.
Sufficient me is herefore allo d after the re tred pressure an flow are achieved to rform this SR Adequate pressurp'at which this SR i to be performe is greater than equal to the I Eloctrp Hydraulic Contr (EHC) System m mum pressure se /
'with4HCcontrollin ressure (EHC beg) s controlling pyessure at a nom 1 150 psig).
Apet;uate steam flow 's
> represented by least 3 turbin ypass valves ope.
IReactor star is allowed pri to performing t,tWs SR
,because va e OPERABILITY anpthe setpoints fo overpressure '
protect are verified, jpet ASME requireme valve
, prior to installation.
Th refore, this SR i modified by 9
No that states the drveillance is no required to e rformed until 12 ours after reac steam pres e and flow are adequa to perform the The 12 rs allowed for mcnual ac ation after the quired press e is reach is suffici to achieve stab conditions d provides tadequate me to complete Surveillan SR 3.5.1 and
- the L C SYSTEM FUNCTIO TEST perfo ed in LCO 3
.5.1 flove ap this Surveill e to provide emplete tes ng of the sumed safety func on.
(continued)
PBAPS UNIT 2 B 3.5-16 Revision No.
ECCS-Operating B 3 5.1 0
BASES SURVEILLANCE SR 3.5.1.12 (continued)
REQUIREMENTS The month Fr uency is ba d on the n to perfpfe the Su eillance der the co tions tha pply just4rior to during startuo fro plant ou e.t operating experience has shown that these components will pass the SR when performed at the 24 month Frequency, which is based on the refueling cycle.
to be acceptable.from a reliability standpoint.Therefore, theI l
t REFERENCES 1.
UFSAR, Section 6.4.3.
1 2.
UFSAR, Section 6.4.4.
3.
UFSAR, Section 6.4.1.
4.
UFSAR, Sections 4.4.5 and 6.4.2.
5.
UFSA2, Section 14.6.
6.
7.
NEDC-32163P, " Peach Bottom Atomic Power Station Units 2 and 3 SAFER /GESTR-LOCA Loss of Coolant Accident Analysis," January 1993.
8.
9.
Memorandum from R.L. Baer (NRC) to V. Stello, Jr.
)
(NRC), " Recommended Interim Revisions to LCOs for ECCS l
Components," December 1,1975.
i 10.
UFSAR, Section 10.17.6.
l l
PBAPS UNIT 2 8 3.5-17 Revision No.-0
SRVs and SVs 3.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 Verify the safety funccion lift setpoints In accordance of the required SRVs and SVs are as fellows:
with the Inservice Testing Program Number of Setpoint SRVs (osio) 4 1135 t 11.0 4
1145 t 11.0 3
1155 12.0 Number of Setpoint SVs (osio) 2 1260 13.0
/ NOTE-/
SR 3.4.3.2 Not equired to/e perfo ed until 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />' af er reactor pteam pre ure and ow are w m ?snud)
Verify each required _SRV g hen T M 24 months i
i l
PBAPS UNIT 3 3.4-9 Amendment No. 8
SRW and SVs B 3.4.3 SASES SURVEILLANCE SR 3.4.3.2 REQUIREMENTS (continued)
A manual uation of ea required SRV performed to verify t, mechanica y, the valve i functioning and n lockage exis in the valve scharge line. prope y can e demonstrate y the respons of the turbine co rol Th v ves or bypass alves, by a ch e in the measure steam ow, or by an Adequate rea other method s ' able to verify s or steam dome p am flow.
perform th test to avoid ssure must be av ' able to adequate team flow must aging the valve. Also,
)
passing through a main turbi f
or tur ' ne bypass valve to continue to co rol reactor pres re when the SRV divert steam flow S
W-a#E#A icient time is erefore allowed a er the requir pon opening.
essure and flowAre achieved to pe orm this test Adequate pressure at which this te greater than pr' equal to the Ele is to be pe rmed is ro-Hydraulic ntrol System minimum pressure set wi EHC controlliyrg pressur(eEHC)
(EHC begir3s' controlling press Adequate / steam flow e at a nominaV150 psig).
bypassAalves open. is reprjes,ented by at 1 st 3 turbin Plany startup is all ed prior to per sfming this test bepeuse valve OPE oints for overpressure protection ILITY and t de requirements, prior to valve i re verified, per ASME allation.
erefore this SR is modifie# by a Note that tates the S veillance,
,is not required J6 be performed i steam pressure /and flow are adt til 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> /after reacto The 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Allowed for mantyt actuationunte to perf the test.
pressure 1 ' reached is suffjtient to achi er the requ ed 7
conditions for testing and'provides a r e stable sonable time o complete' the SR.
If a
'Ive fails to ctuate due o y to the fa'ilure of the sol oid but is c able of open' g on ove/ pressure, the sa ty function o the SRV is nsidered pRABLE.
The 4 month Fr uency is bas S veillance der the condi on the need Jo perrorm tny ens that app}f just prior go during a artup from aj lant outage.
' Operating when performed at the 24 month Frequency, wh the refueling outage. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.
REFERENCES 1.
NEDC-32183P, " Power Rerate Safety Analysis Report for _
Peach Bottom 2 & 3," May 1993.
I 2.
UFSAR, Chapter 14.
i PBAPS UNIT 3 8 3.4-18 Revision No.
ECCS-Operating 3.5.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.1.12
-__-- -_-------- f f
/
-NOTE--
'Not, required to
_7 eam pressu [and flow e performe until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> affer reactor e
'e equate to rform the st.
Verify each Ans valve aa-unen minuallyQnmwx srmat 24 months WS'WM'W]
l PBAPS UNIT 3 3.5-7 Amendment No.41
_D
ECCS-Op; rating B 3.5.1 BASES SURVEILLANCE SR 3.5.1.11 (continued)
REQUIREMENTS pass the SR when perfomed at the 24 month Frequency, which is based on the refueling cycle.
was concluded to be acceptable from a reliabilityTherefore
-standpoint.
This SR is modified by a Note that excludes valve actuation.
This prevents an RPV pressure blowdown.
SR 3.5.1.12 A manual actuat n of each Aud Ive is performed that the val and solenoid functioning pro ly and verify that no bl age exists in e S/RV discharg ines. This is demo rated by the ponse of the tur ' e control or h
bypa valve or by a ange in the meas d steam flow or by
(
a other method s able to verify am flow. Adequate eactor steam p ssure must be ava able to perform this 5gg w,5 g;eyjy test to avoi amaging the valv. Also, adequate ste flow must be p ing through the i n turbine or turbine valves continue to cont i reactor pressure w the ADS ypass valv divert steam fl pon opening.
Suffi ' nt time is t
efore allowed af the required press and flow are chieved to perfo this SR. Adequate p ssure'at which this SR is to b perfomed is greater an or equal to the Electro-Hydr ic Control EHC trolling pressu(re ) Sy a minimum pressure t
with EHC begins controllin pressur at a nominal 150 p Adequate steam f w is repr ented by at least 3 bine bypass valves IR ctor startup is allowe prior td performi this SR en.
ecause valve OPERABR4TY and the setpoin for 'overpress protection are ve ied, per ASME requi ments, prior t valve installa n.. Therefore, this is modified a
Note that s es the Surveillance '
performed /ntil12hoursafter not required be flow ape adequate to perform actor steam pr sure and e test.
The 1 ours allo fo anual actuation afte he required pr sure is reach ufficient to achiev stable conditi and provides dequate time to co ete the Surveil nee. SR 3.5.
I and the LOGIC SYSTEM CTIONAL TEST p ormed in LCO (3.5.1 overlap this S eillance to pro de complete t ing of the assumed safe function.
(continued)
PBAPS UNIT 3 B 3.5-16 Revision No.
4 ECCS--Operating
+
B 3.5.1 BASES SURVEILLANCE SR 3.5.1.12 (continued)
REQUIREMENTS The J4 montn Fr uency is sed on the ed to perA rm the Su 'eillance der the c ditions tha apply jusYorior tol durino a tartuo fr a slant ou_ e.1 Operating expertence nas shown that taase components will pass the'SR when performed at the 24 month Frequency, which is based on the refueling cycle.
to be acceptable from a reliability standpoint.Therefore, th REFERENCES 1.
UFSAR, Section 6.4.3.
2.
UFSAR, Section 6.4.4.
3.
UFSAR, Section 6.4.1.
4.
UFSAR, Sections 4.4.5 and 6.4.2.
5.
UFSAR, Sectior 14.6.
6.
10 CFR 5C, Appendix K.
7.
NEDC-32163P, " Peach Bottom Atomic Power Station Units 2 and 3 SAFER /GESTR-LOCA Loss of Coolant Accident l
Analysis," January 1993.
8.
9.
Memorandum from R.L. Baer (NRC) to V. Stello, Jr.
(NRC), " Recommended Interim Revisions to LCOs for ECCS Components," December 1,1975.
10.
UFSAR, Section 10.17.6.
PBAPS UNIT 3 8 3.5-17 Revision No.
INSERT A SR 3.4.3.2 The pneumatic actuator of each SRV valve is stroked to verify that the second stage pilot disc rod is mechanically displaced when the actuator strokes. Second stage pilot rod movement is determined by the measurement of actuator rod travel. The total amount of movement of the second stage pilot rod from the valve closed position to the open position shall meet criteria established by the SRV supplier, if the valve fails to actuate due only to the failure of the solenoid, but is capable of opening on overpressure, the safety function of the SRVis considered OPERABLE.
l l
e*
INSERT B SR 3.5.1.12 i
i The pneumatic actuator of each ADS valve is stroked to verify that the second
)
stage pilot disc rod is mechanically displaced when the actuator strokes. Second stage pilot rod movement is determined by the measurement of actuator rod I
travel. The total amount of movement of the second stage pilot rod from the valve closed position to the open position shall meet criteria established by the S/RV supplier. SRs 3.3.5.1.5 and 3.5.1.11 overlap this Surveillance to provide testing of the SRV depressurization mode function.
i i
I l
l l
l-l l
\\;
h l
i l
ATTACHMENT 3 PEACH BOTTOM ATOMIC POWER STATION l
UNITS 2 AND 3 Docket Nos. 50-277 l
50-278 License Nos. DPR-44 DPR-56 Relief Request 01 A-VRR-1 l
l t
i r
e.
i VALVE RELIEF REQUEST - 01 A-VRR-1 System:
Main Steam / Automatic Depressurization System (ADS)
Valve (s):
RV-2-02-07.1 A, B, C, G, K; RV-3-02-071 A, B, C, G, K Category:
B (ADS mode), C gelf-actuating mode)
Function:
.Depressurization of the RCS to allow for low pressure i
coolant injection, and overpressure protection.
Testing Requirement (s):
Quarterly exercise and stroke time per ISTC 4.2.
Remote c:tuation at reduced system pressure to verify open and closed capability per the ASME OM Code - 1990 Edition, Appendix 1, paragraph I 3.4.1(d).
Basis for Relief:
In-situ exercising testing of the ADS Safety Relief Valves (SRVs) imposes an unnecessary challenge on I
the valves and has been linked to valve degradation l
(e.g., second stage disc leakage). Second stage disc
]
leakage could, if severe enough, result in inadvertent I
valve actuation resulting in a plant transient. If any of these valves fail to re-close after testing, the plant would be required to shutdown in accordance with Technical Specification 3.6.2.1, " Suppression Pool Average Temperature."
BWR Owner's Group Evaluation of NUREG-0737, item II. K.3.16," Reduction of Challenges and Failures
)
of Relief Valves" recommends that the nurnber of ADS openings be reduced as much as possible.
Additionally, Recent ASME Code development has recognized that unnecessary challenges to ADS valves should be avoided. ASME Code OMb - 1997, Subsection ISTC, Paragraph 1.2, excludes safety and relief valves from the requirements of ISTC 4.1, Valve Position Verification, and ISTC 4.2, inservice Exercising Test.
i L
Functional testing at power of the ADS /SRVs is not necessary because the remaining ADS and SRV tests provide an acceptable level of reliability and plant safety.
These remaining tests and the associated ADS /SRV performance requirements provide adequate demonstration of ADS /SRV operability as described below:
A. ASME OM Code - 1990 Edition, Appendix 1, Setpoint/ Leakage Testing As required by ASME OM Code - 1990 Edition, 1
c.;
Appendix 1, during each refueling outage, which occurs on a 24 month frequency, approximately 50% of the SRVs (currently the entire valve assembly) are removed and shipped to an offsite testing facility for "as-found". testing. Testing is performed in accordance with the offsite testing facility procedure.
This testing includes visual inspection, leakage testing, valve body _ leakage testing, delay time testing, and set pressure testing (i.e., TS setpoint limits), all of which are performed prior to any maintenance on the valve.
The seat leakage test is performed at a steam i
pressure of approximately 1040 psig and set I
pressure testing is performed at the Technical J
Specification lift setpoints.
Following the "as-found" testing, the SRVs undergo a dimensional inspection if valve refurbishment is required. This refurbishment is performed by the valve supplier, currently Target Rock Corporation.
If valve refurbishment is
- required, post-maintenance testing is performed. This testing includes visual inspection, leakage testing, valve body !eakage testing, delay time testing, and set pressure testing (i.e., TS setpoint limits). The final seat leakage test is performed at approximately 1040 psig. Upon successful test completion, the i
valve receives written certification from the lab and is returned to PBAPS for reinstallation. To receive certification, the valve must have zero seat leakage and meet the acceptance criteria for set pressure. These tests satisfy the requirements of the ASME OM Code - 1990 Edition, Appendix 1, and are also used to satisfy the requirements of TS SR 3.4.3.1 for lift setpoint pressure verification.
The test satisfies the verification of the safety mode function.
B. ADS Logic System Functional Test Per TS SR 3.3.5.1.5, a logic system functional test is performed every 24 months which demonstrates the operability of the required initiation logic for the ADS.
C. ADS Simulated Automatic Actuation Test Per Technical Specification SR 3.5.1.11, testinp is performed each cycle that verifies that individual channel calibrations and functional tests of the 2
g4 -
o ADS have been satisfactorily comp!ated within 24 months. The satisfactory completion of all tests listed in this procedure satisfies the simulated automatic actuation testing requirement of Technical Specification SR 3.5.1.11.
D. ADS Supply Instrument Gas / Accumulator Leakage Test l
The ADS aupply instrument gac/ accumulator leakage is tested every 24 months in accordance with the PBAPS inservice Testing (IST) Program, and each time maintenance is performed on the ADS valve, to ensure that there will be sufficient l
pneumatic pressure to actuate the valve.
l In addition to the above described tests which are currently performed on the SRVs, PECO Energy proposes that the current testing contained in TS SR 3.4.3.2 and 3.5.1.12 be revised to energize the solenoid, stroke the actuator, and verify second stage disc movement of all 11 SRVs in the depressurization mode.
These combined tests described above verify all required ADS critical component performance requirements. This relief request will only eliminate the post-installation stroke timing via the auxiliary actuating device (i.e., the solenoid mode).
Stroke time testing is currently performed by indirect means through the detection of steam flow by I
acoustic monitoring. For fast acting valves such as these, the practice of measuring stroke times is of limited value in detecting degradation.
Alternate Testing:
TS SR 3.4.3.2 and 3.5.1.12 will serve as the IST exercise test.
)
l l
l i
3 1
-_____