Text

Proposed Tech Specs,Allowing Greater Flexibility in Isolating Reactor Makeup Water Supply to RCS During Refueling Operations
	ML20248H303
Person / Time
Site:	McGuire, Mcguire
Issue date:	10/06/1989
From:	; DUKE POWER CO.
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l U,$.' Nucle r Regulatory Commission

-Document' Control Desk October 6, 1989 li Attachment No.1 McGuire Nuclear Station Proposed Changes To Technical Specification e

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PDR ADOCK 05000369 P

PDC

y1 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION LIMITING CONDITION FOR OPERATION 3.9.1. The boron concentration of all filled portions of the Reactor Coolant System and the refueling canal shall be maintained uniform and sufficient to ensure that the more restrictive of the following reactivity conditions is met:

Either a K,ff of 0.95 or less, or a.

A baron concentration of greater than or equal to 2000 ppe.

b.

MODE 6*, with the reactor vessel head closure bolts less than APPLICA8ILITY:

fully tensioned or with the head removed.

1 ACTION:

With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes and initiate and continue boration at greater than or equal to 30 gpm of'a solution containing greater than' or equal to 7000 ppe boron or its is reduced to less than or equal to 0.95 or the boron equivalentuntilK[(oredtogreaterthanorequalto2000 ppa,whicheveris concestrationisrI the more restrictive.

SURVEILLANCE REQUIREMENTS The more restrictive of the above two reactivity conditions shall be 4.9.1.1 determined prior to:

Removing or unbolting the reactor vessel head, and a.

Withdrawal of any full length control rod in excess of 3 feet from b.

its fully inserted position within the reactor vessel.

The boron concentration of the Reactor Coolant System and the 4.9.1.2 refueling canal shall be determined by chemical analysis at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

l 200 ;b;il t; w;rifi;d ;1;;;d.ad;r ;d;ini;tr;tiv; ;;ntr;! 14-4.9.1.3 h n t u n ;;7 70 he c;.

Rep (q c e, a,tk f,;l' d ' 9 P y e-

"The reactor shall be maintained in MODE 6 whenever the head removed.

___.---- D 9& M - E ITS_1 and 2 3/4 9-1

U.$.' NuclearLR: gulatory Commission Document Control Desk s

October 6, 1989 Insert the following at TS 4'.9.1.3:

Verify the Reactor Makeup Water Supply to the Chemical and Volume Control System is' isolated under administrative controls once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

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3/4.9 REFUELING OPERATIONS BASES 3/4.9.1 BORON CONCENTRATION The limitations on reactivity conditions during REFUELING ensure that:

(1) the reactor will remain subcritical during CORE ALTERATIONS, and (2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel.

These limitations are consistent with the initial conditions assumed for the boron dilution incident in the accident analyses.

The value of 0.95 or less for K,ff includes a 1% delta k/k conservative allowance for uncertainties.

Similarly, the boron concentration value of 2000 ppm or greater includes a conservative uncertainty allowance of 50 ppa boron.

In wE na i +h fo il o u!'N Pop 3/4.9.2 INSTRUMENTATION The OPERABILITY of the Source Range Neutron Flux Monitors ensures that redundant monitoring capability is available to detect changes in the reactivity condition of the core.

3/4.9.3 DECAY TIME The minimum requirement for rer.ctor subcriticality prior to movement of irradiated fuel assemblies in the reactor vessel ensures that sufficient time has elapsed to allow the radioactive decay of the short-lived fission products.

This decay time is consistent with the assumptions used in the accident analyses.

3/4.9.4 CONTAINMENT BUILDING PENETRATIONS The requirements on containment building penetration closure and OPERA 8ILI~-

of the Reactor Building Containment Purge Exhaust System HEPA filters and charcoal adsorbers ensure that a release of radioactive material within con-tainment will be restricted from leakage to the environment or filtered through I

the HEPA filters and charcoal adsorbers prior to discharge to the atmosphere.

The OPERABILITY and closure restrictions are sufficient to restrict radio-active saterial release from a fuel element rupture baseo upon the lack of Operation containment pressurization potential while in the REFUELING MODE.

of the Reactor Building Containment Purge Exhaust System HEPA filters and charcoal adsorbers and the resulting iodine removal capacity are consistent with the assumptions of the accident analysis.

The methyl iodide penetration test criteria for the carbon samples have been made more restrictive than required for the assumed iodine removal in the accidert analysis because the humidity to be seen by the charcoal adsorbers may be greater than 70% under normal operating conditions.

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l McGUIRE - UNITS 1 and 2 8 3/4 9-1 J

U.S. Nuclear Regulatory Commission Document Control Desk October 6, 1989 Insert the following at the end of Bases 3/4.9.1 Boron Concentration:

l The Reactor Makeup Water Supply to the Chemical and Volume Control (NV) System is I

normally isolated during refueling to prevent diluting the Reactor Coolant System boron concentration.

Isolation is normally accomplished by closing valve NV-250.

Ilowever, isolation may be accomplished by closing valves NV-131, NV-140, NV-176, NV-468, NV-808, and either NV-132 or NV-1026, when it is necessary to makeup water to the Refueling Water Storage Tank during refueling operations.

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i; U.$.NuclearRrgulatoryCommission

. Document Control Desk October. 6',

1989 Attachment No. 2 McGuire Nuclear Station F-Technical Discussion, No Significant Hazards Analysis, and I-Environmental Impact Analysis

_----.-_.-----_.a------.a

.U3.[NuclearRegulatoryCommission

. Document Control Desk:

October 6, 1989 i

Attachment No. 2

' Technical: Discussion, No Significant-Hazards Analysis'and Environmental Statement s

Description of Proposed Changes l Technical Specification (TS) 3/4.9.1 requires valve NV-250 to be verified closed under administrative' controls at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ..

The' proposed revision will:

Change this requirement so the reactor makeup water supply to the Chemical and. Volume Control' system would be verified as isolated under administrative controls once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; and, Change the' Bases, 3/4.9.1,. Boron Concentration, by adding a paragraph to

-explain why.the reactor makeup water supply to the Chemical and Volume Control, system is isolated. This change would also describe two options operators could use to perform the isolation.

Justification / Technical Discussion Prior to. refueling, McGuire floods the refueling cavity using borated water from

'the Refueling Water Storage Tank (RWST). After flooding the refueling cavity, the RWST water volume is-just above the required volume of 26,000 gallons. Technical Specification (TS)'3.1.2.5 requires a minimum volume of 26,000 gallons of water in the RWST,during Modes 5 and 6.

Also during refueling operations, TS 3/4.9.1 requires valve NV-250 to be closed to prevent the inadvertent dilution of the Reactor Coolant system boron concentration. During past outages, an alternative valve boundary has been used.when necessary instead of maintaining valve NV-250.

' closed with the understanding that the TS requirement was satisfied by documenting the "out-of-normal" valve alignment in the Operations Removal and Restoration procedure. With increased emphasis on ensuring proper procedural guidance for Operators, it was decided to provide specific procedural guidance for utilizing l

valve NV-250 or an alternative valve alignment to satisfy the intent of the TS l_

surveillance. It was also decided that a TS interpretation was required to support L

the justification for the deaired procedure change. In pursuing the TS l

interpretation, the McGuire NRC Senior Resident Inspector made clear his opinion that although the intent of the TS surveillance would be satisfied by use of the alternative valve alignment, the interpretation should not be approved since a specific component (valve NV-250) is designated in the current TS surveillance wording. It is now obvious that what was thought to be acceptable in the past is no longer acceptable without first obtaining a change to surveillance requirement of TS 3/4.9.1 regarding valve NV-250.

During refueling operations, the RWST is at its lowest inventory level after flooding the refueling cavity.

It is normally maintained just above the TS required minimum level for Mode 6, Refueling. This is necessary to maintain sufficient empty volume space in the RWST to empty the contents of the refueling cavity after refueling. During refueling, the remaining RWST inventory may be used for various needs, such as filling systems being returned to normal alignment after maintenance, testing activities, or for maintaining refueling cavity level. ---_--_--_:-_--__-_

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U;S. Nuclear Regulatory Commission Document Control Desk October 6, 1989 Attachment No. 2 It is typical for makeup to the RWST, during refueling to maintain its TS required level, to occur 1 to 3 times. This frequency is governed primarily by the amount of water lost from the refueling cavity, spent fuel pool, Reactor Coolant system, Residual Heat Removal system, Chemical and Volume Control system, Fuel Pool Cooling system, other interconnecting systems, and by the number of drained components and portions of systems returned to functional status during this time period. This volume of water ranges from 5000 to 10,000 gallons. Each requirement for makeup normally takes 8 to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Normally, it takes 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to unload the reactor core, and 120 hours0.00139 days 0.0333 hours 1.984127e-4 weeks 4.566e-5 months to reload the core. Interrupting refueling, even for what seems to be relatively short periods of time has a significant impact on outage scheduling. If refueling is critical path during the outage, which will be the case for most future outages, the economic impact is significant (resource allocation and increased cost for replacement power). The additional startup and shutdown of sensitive refueling equipment results in unnecessary wear and tear, and the increased possibility of equipment problems.

Using the proposed alternative valve alignment, to allow makeup to the RWST and refueling operations to occur concurrently,.would eliminate the above mentioned i

I problems and would result in an equivalent level of protection against a boron dilution event as the existing TS.

In summary, the proposed change to the TS would allow continued ficxibility in scheduling outage activities without compromising the protection of the Reactor Coolant system.

The Reactor Makeup Water Supply to the Chemical and Volume Control (NV) system is normally isolated during refueling to prevent diluting the Reactor Coolant system boron concentration.

Isolation is accomplished per TS by closing valve NV-250.

However, if allowed by TSs, isolation could be accomplished by closing valves NV-131, NV-140, NV-176, NV-468, NV-808, and either NV-132 or NV-1026. Thin valve alignment would be desirable when it is necessary to makeup water to the Refueling Water Storage Tank during refueling operations. With valve NV-250 closed, this operation cannot be accomplished.

During refueling operations TS 3/4.9.1 provides limits for reactivity conditions so the reactor will remain subcritical during core alterations and so a uniform boron concentration is maintained in the water volume having direct access to the reactor vessel. During refueling, the following conditions exist: 1) One Residual Heat Removal (ND) pump is operating to ensure continuous water mixing in the reactor vessel; 2) The reactor makeup control systen is adjusted for addition of boric acid solution at the refueling concentration; 3) One charging pump is normally inoperative, and one charging pump is racked out and declared inoperable;

4) The boron concentration in the refueling water is approximately 2000 ppm; 5)

The source range detectors outside the reactor vessel are active and provide an audible count rate; and, 6) A high flow alarm at the discharge of the Chemical and Volume Control (NV) system is active providing an alarm to the operator when the flow rate from the charging pump exceeds 175 gpm.

Three potential paths exist for the introduction of reactor makeup water to the suction of the charging pumps. The first is the two inch line including valve NV-262, which is normally closed. The other two paths are through two inch lines, one line leading to the Volume Control Tank (VCT), and the other line by-passing the VCT. These lines contain flow control valves NV-171 and NV-175A respectively. _ _ _ _ _ _ - _ - _ _ _ _

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U!S. Nuclear'Regulatbry Commission Document Control Desk October 6, 1989

Attachment 2 This flow path is isolated by closing valve NV-250. For delivery of the FSAR analysis assumed 200 gpm of unborated water through these paths, (see FSAR Section 15.4.6.3.2), the following conditions must exist: 1) The' operation of the normally Inoperative charging pump; 2) The operation of the normally inoperative reactor

- makeup water subsystem, at sufficient capacity to provide 200 gpm to the NV system; and, 3) An open path from the reactor makeup water subsystem to the charging pumps suction.

In order for dilution to occur, an operator would have to take several independent actions. consciously ~ directed to water makeup. The operator would have to set the mode' selector switch to manual or dilute, set the boric acid and makeup flow controllers to the desired flow rates, set the boric acid and makeup water batch integrators to the desired quantities, actuate the switch, and finally start a Lcharging pump. The flow alarm discussed in Item 6 above provides an additional indication to the operator if the dilution flow rate into the Reactor Coolant (NC) system exceeds the values assumed in the McGuire FSAR analysis. The only way this sequence of events could occur is through the conscious action of an operator. In addition, for the following 57 minutes, the operator and refueling personnel must be oblivious to any indications of a dilution, including a continually rising audible alarm rate from the source range monitor.

In addition to unit. alarms and core monitoring systems used to provide protection against boron dilution accidents during refueling, administrative controls are employed to' isolate the NC system from these potential sources of unborated water. Valve NV-250 is

-administrative 1y locked closed blocking the potential flow paths which could allow delivery of unborated makeup water to the NC system via the NV charging pumps, (see attached drawing).

McGuire Technical Specification (TS) 4.9.1.3 surveillance requirement specifically states that " valve NV-250 shall be verified closed under administrative controls at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months " during refueling operations. Subsequently, we have imind this TS requirement does not provide adequate operational flexibility when it la ecessary to makeup water to the Refueling Water Storage Tank (RWST). Valve NV-250'mu m be in the open position to makeup watar to the RWST. The proposed TS amendment would add an optional valve alignnent that will also isolate potential flow paths which could deliver unborated water to the NC system via the NV system, allowing operators to makeup water to the RWST.

Makeup water is provided to the RWST by pumping water to the boric acid blender with a reactor makeup water pump concurrent with boric acid solution being pumped to the blender with a boric acid pump. With the optional valve alignment, valve NV-250 would be open allowing the borated water to be pumped to the RWST.

The following valves would be closed as an alternative to closing valve NV-250 providing isolation to prevent delivery of unborated makeup water to the NC system: - - _ _ _ _ _ - _

U.'S. Nuclear Regulatory Commission Document Control Desk October 6,.1989 Valve NV-176, Boric Acid. Blender Discharge to Volume Control Tank Outlet; Valve NV-140, Volume Control Tank Inlet. Isolation; Valve NV-131, Boronometer Inlet Isolation; Valve NV-468, Boric Acid Blender Outlet Sample; Valve NV-808, Boron Meter Flush Supply; and, Valve NV-1026, Boronometer Inlet Isolation; or Valve NV-132, Boronometer Outlet Isolation.

NOTE: See attached FSAR drawings for valve locations.

Therefore, we propose to change TS 4.9.1.3 to read the following:

" Verify the' Reactor Makeup Water supply to the Chemical and Volume Control System is isolated under administrative controls once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ."

Additionally, to provide an adequate level of administrative control, the Unit 1 and 2 controlling procedures for unit shutdown, OP/1/A/6100/02 and OP/2/A/6100/02 respectively, will be revised to include the following requirement prior to entry to Mode 6:

White Tag closed Reactor Makeup Water to the NV system by completion of one of the two steps below:

(1) Tag NV-250 (Reactor Makeup Water to the NV system) closed.

NOTE: The following step will provide RWST makeup capability.

(2) Tag closed the following valves.

NV-176 (Boric Acid Blender Disch to VCT Outlet);

NV-140 (VCT Inlet Isolation);

NV-131 (Boronmeter Inlet Isolation);

NV-468, Boric Acid Blender Outlet Sample; NV-808, Boron Meter Flush Supply; and, NV-1026 (Boronmeter Inlet Isolation) or NV-132 (Boronmeter Outlet Isolation) l The Unit 1 and 2 Daily Surveillance Procedures, PT/1/A/4600/03B and PT/2/A/4000/03B respectively, will be changed to properly document surveillance of the chosen method of isolation.

The proposed revision would also change the Bases, 3/4.9.1, Boron Concentration, by adding a paragraph explaining why the Reactor Makeup Water supply to the Chemical and Volume Control system is isolated, and describe the available options operators can use to accomplish this isolation. L__________

4 U.$. Nuclear Regulatory Commission i

Document Control Desk October 6, 1989 Significant Hazards Analysis During refueling operations, the revised TS will continue to provide an equal level of protection for reactivity conditions as the existing TS to ensure the reactor remains suberitical during core alterations.

The proposed TS change will allow greater operational flexibility by giving the operators the ability to makeup water to the RWST during refueling. The isolation of valve NV-250, or the isolation of valves as provided by the optional valve j

alignment will block the potential flow paths that could allow unborated makeup water to reach the NC system by way of the NV charging pumps. The same administrative controls will continue to be used for isolation under the optional valve alignment provided by the proposed change.

The preposed revision will also change the Bases, 3/4.9.1, Boron Concentration, by adding a paragraph to explain why the reactor makeup water supply to the Chemical and Volume Control system'is isolated, and to describe the two operator options that may be used to provide adequate protection against a boron dilution event during refueling operations.

The proposed changes will not increase the probability or consequences of an accident previously evaluated. Accidents involving a malfunction of the NV system that would result in a decrease in boron concentration in the NC system during refueling are presented in McGuire FSAR Section 15.4.6.3.2.

Valve NV-250 isolates against the same potential flow path as the new valve alignment will isolate.

Although there are more valves to isolate, each valve will be individually isolated using McGuire's Red Tag system; therefore, the same level of administrative controls will be employed on this new valve alignment. The use of more than one valve for isolation could be considered an increase in the probability for error, but the controls of the Red Tag program on each individual valve make this increase insignificant. There will be no changes in the operation, or boron concentrations of the NV system or the NC system as a result of the proposed change.

The accident assumptions, effects, and consequences will not change as a result of the proposed revision. A dilution event during refueling under the proposed TS controls cannot occur without the conscious action of the operator. However, for the purpose of the FSAR analysis, these operator actions are assumed to occur. Even so, there is adequate time (57 minutes) for the operator to recognize the high count rate signal and manually terminate the dilution. The proposed change does not alter this analysis.

The proposed changes will not create the possibility of a new or different kind of accident from any previously analyzed. The proposed change does not introduce any new equipment or hardware, and no equipment is operated in a new or different manner during power operations. By operating the systems during refueling according to the proposed revision, the NC and NV systems will be operated the same as before except for the provision that allows makeup to RWST. Operation of the makeup water system will not affect boron concentration in the NC system.

With the new valve alignment, the same level of protection against a boron intrusion event exists as does with valve NV-250 closed. !

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U 3. Nuclear Regulatory Commission Document Control Desk-October 6, 1989 The proposed changes will not involve a reduction in the margin of safety.

Assuming the failure of either valve alignment allowed by the proposed revision, the time for the operator to recognize that boron dilution has occurred and to manually terminate the dilution event has not changed.

The FSAR analysis, as previously discussed, will not change as a result of using the new valve alignment as provided by the proposed change.

The same margin of safety exists as previously did with valve NV-250 closed.

Therefore, we conclude that the proposed revision does not involve a significant hazards consideration.

Environmental Impact Analysis:

The proposed change has been reviewed against the criteria of 10CFR51.22 for the environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increases the types and amounts of effluents that may be released effsite, nor increases individual or cumulative occupational radiation exposures. Therefore, the proposed TS change meets the criteria given in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.

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