ML20247K726

Safety Evaluation Supporting Amend 105 to License DPR-54

ML20247K726
Person / Time
Site:	Rancho Seco
Issue date:	05/23/1989
From:	Office of Nuclear Reactor Regulation
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ML20247K709	List: ML20247K706 ML20247K712 ML20247K726
References
NUDOCS 8906010372
Download: ML20247K726 (5)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACT 0P REGULATION SUPPORTING AMENDMENT NO.105 TO FACILITY CFERATING LICENSE DPR-54 RANCHO SECO NUCLEAR GENERATING STATION, UNIT 1 DOCKET NO. 50-312

1.0 INTRODUCTION

By letters datea October 7,1988, November 18, 1988, and March 27, 1989, the Sacramento Municipal Utility District (SMUD) requested en amendment to the Technical Specifications (TS) appended to Facility Operating License No. DPR-54 for Rancho Seco Nuclear Generating Station. The proposed amendment would change the TS by revising (1) TS 3.4 to clarify the operational  ;

mode applicability of that specification and the definition of Auxiliary Feedwater(AFW) train,and(2)TS4.8tochangethesurveillance requirements and frequency of verifying the AFW System flow path, modify a surveillance requirement to reflect the installation of an alternate flow path for AFW pump testing and remove the requirement for conducting system testing following cold shutdowns longer than 30 days, excluding refueling shutdowns. Specifically there are five proposed changes, as follows:

a. Modify TS 3.4.1 and 3.4.2 to clarify the reactor operating conditions in which these respective TS apply.

b. Modify TS 3.4.1.E and 3.4.2.F to clarify the definition of " auxiliary feedwater trains."

c. Change the references to "SFW" (Startup Feedwater) in TS 3.4.1.G and 3.4.2.I to reflect that the startup valves are part of the Main Feedwater (MFW) System,

d. Modify TS 4.8.1 to reflect alternate flow paths available for AFW pump testing and lower the reactor coolant system average temperature above which the AFW system is to be tested. ,

c. Modify TS 4.8.3 to allow only AFW flow path valves not locked or sealed to be verified monthly to ensure that the valves are in the proper position and add TS 4.8.4 to require that those AFW valves manipulated for surveillance testing or maintenance be verified upon completion of the surveillance or maintenance to ensure the valves are in the proper position. (Existing TS 4.8.4 is renumbered to  ;

TS4.8.5) l

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2.0 . EVALUATION The hRC staff-has evaluated the proposed changes and has concluded that.

they are acceptable. The staff's evaluation is provided below.

a. Applicable Reactor Operating Conditions for TS 3.4.1 and 3.4.2 Currently, TS 3.4.1 does not have an upper boundary on the operational modes in which the Specification applies and TS 3.4.2 is applicable L when the reactor is " critical." The licensee. proposes to clarify the reactor operating conditions in which the respective specifications apply by the following: (1) In TS 3.4.1, expand the term "above 280*F" to "above 280*F thru HOT SHUTDOWN": and (2) In TS 3.4.2, re-place the term " remain critical" with "in the STARTUP through POWER OPERATION mode." Thus, the applicable operating conditions are clearly defined. The NRC staff finds this change to be acceptable.

b. Definition of Auxiliary "Feedwater Trains" Currently TS 3.4.1 and 3.4.2 use the term "Both auxiliary feedwater trains" and the licensee proposes to clarify this term by indicating the specific. valves in specific flow paths thus clarifying the equipment required to constitute an operable train. The NRC staff finds this change to be acceptable.

c. "SFW"(StartupFeedwater)

Currently, TS 3.4.1.G and 3.4.2.I reference "SFW" (Startup Feedwater).

The reference implies an independent Startup Feedwater System when it actua11y' refers to the startup valves of the Main Feedwater (MFW)

System. The licensee proposes to eliminate this confusion by changing "SFW" to "(including MFW startup valves)". Thus the affected systems and components in TS 3.4.1.G and 3.4.2.1 are clearly identified. The NRC staff finds this change to be acceptable.

d. Alternate Flow Paths for AFW Pump Testing Currently, TS 4.8.1 directs that AFW pump verification be performed by operating the pumps "on recirculation to the condenser." An alternate flow path is being installed that provides for recirculation to the Condensate Storage Tank (CST) for AFW pump testing. The licensee proposes to delete the words "to the condenser," which would allow the flexibility to test the AFW pumps via a flow path from the CST to the condenser hot well, recirculation of water to the CST, or other alternate flow paths. The acceptance criteria for acceptable pump performance and operability are not changed or modified and remain specified in TS 4.8.1. Thus, the operability requirements for the AFW pumps are not affected. The NRC staff finds this to be acceptable. Also, in TS 4.8.1, the licensee proposes to change the RCS temperature at or above which the AFW pumps are tested from 305'F

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to 280'F. This change'is proposed to be consistent with AFW System operability requirements stated in TS 3.4.1. Lowering the RCS ,

temperature limit is a conservative, more restrictive change and D therefore the NRC staff finds it to be acceptable.

e. Verification of AFW System Flow Path Currently, TS 4.8.3 requires all AFW valves, including those that are locked, sealed, or otherwise secured in position, to be inspected following all surveillance performed pursuant to Specifications 4.8.1, 4.8.2, and 4.8.4. The licensee proposes to change TS 4.8.3 and. add 4.8.5) a new the to require TS 4.8.4 (the existing)TS following: (1 monthly,4.8.4 verify would be renumbered to all auxiliary feedwater system valves that are not locked, sealed or otherwise secured in position are in the proper position, when the average Reactor Coolant System temperature is greater than or equal to 280 F, and (2) verify that all AFW valves manipulated in the performance of maintenance or surveillance performed pursuant to Specifications 4.8.1, 4.8.2, and 4.8.5 are in the proper position.

The NRC performed an evaluation of AFW Systems for various operating plants (NUREG-0611 and NUREG-0635) and made short-term and long-term generic recommendation. In response to the short-term recommendations, the licensee committed to inspect all AFW System valves, including those that are locked, sealed or otherwise secured in position, to verify the proper position. The long-term recommendation to resolve the concern that generated the above short-term recommendation is_to provide redundant parallel flow paths (piping-and valves) to prevent AFW system inoperability due to an inadvertent closed manual valve that could interrupt all AFW system flow. The itcensee has redundant parallel AFW system flow paths, which satisfy this recommendation and resolves the concern.

NUREG-0103, " Standard Technical Specification for Babcock and Wilcox

1. Pressurized Water Reactors," Section 4.7.1.2 (Surveillance Requirements for the Auxiliary Feedwater System) states that each AFW System be demonstrated operable at least every 31 days by: " Verifying that each valve (manual, power-operated or automatic) in the flow path that is

not locked, sealed, of otherwise secured in position, is in its correct position."

The proposed changes to TS 4.8 provide for monthly inspection, when the average RCS temperature is greater than or equal to 280*F, of all flow path valves in the AFW System which are capable of being moved without unlocking or unsecuring. This will ensure proper valve positioning in the AFW System flow path. The proposed changes also provide for post-maintenance and post-testing verification of the proper positioning of all valves that were manipulated during maintenance and testing. This ensures a return to the proper' position of those AFW valves placed in an off-normal configuration, k - - - - - - - - - - - - - - - _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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9 The proposed changes to TS 4.8 ensure periodic verification of the position of AFW System flow path valves which are capable of having their position changed (valves not secured, locked, or sealed).

Administrative controls are presently in place at Rancho Seco to ensure the proper positioning of the remaining AFW System valves.

The positioning and control of locked valves is directed by administrative procedures. The position of all locked valves is verified prior to plant startup after leaving cold shutdown. The correct position of all system valves is verified prior to startup of the respective system. An administrative procedure controls the documentation of the status of equipment and systems. System Lineup Alteration checklists and System Lineup Restoration checklists are used for all system lineups that vary from the position required by the applicable procedure. Technical Specification requirements and in-place administrative controls ensure that all AFW System valves are in their proper position. This ensures the capability of the AFW System to perform its intended function.

Based on the above, the NRC staff finds this acceptable.

3.0 CONTACT WITH STATE OFFICIAL l The NRC staff has advised the Chief of the Radiological Health Branch, State Department of Health Services, State of California, of the proposed determination of no significant hazards consideration. No comments'were received.

4.0 ENVIRONMENTAL CONSIDERATION

This amendment involves changes in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to surveillance requirements. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Comission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding.

Accordingly, this amendment meets the eligibility criteria for categorical exclusionsetforthin10CFR51.22(c)(9). Pursuantto10CFR51.22(b),

no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

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5.0 CONCLUSION

Wehaveconcluded,basedontheconsiderationsdiscussedabove,that(1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the proposed manner, (2) public such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the anendment will not be inimical to comon defense and security or to the health and safety of the public.

Principal Contributor: S. Reynolds Dated: May 23,1989

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