ML23278A117
ML23278A117 | |
Person / Time | |
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Site: | Technical Specifications Task Force |
Issue date: | 10/02/2023 |
From: | Technical Specifications Task Force |
To: | |
References | |
Download: ML23278A117 (1) | |
Text
TSTF-600, Rev. 0 PWROG-18, Rev. 0 NUREGs Affected:
Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler 1430 1431 1432 1433 1434 Classification: 1) Technical Change Recommended for CLIIP?: Yes Correction or Improvement:
Improvement NRC Fee Status:
Not Exempt Benefit:
Reduces Testing Changes Marked on ISTS Rev 5.0 2194 PWROG RISD & PA (if applicable): PA-LSC-1975 RS-2022-019 See attached.
Revision History Affected Technical Specifications OG Revision 0 Revision Status: Active Original Issue Revision
Description:
Revision Proposed by:
PWROG Owners Group Review Information Date Originated by OG:
22-Jun-23 Owners Group Comments (No Comments)
Date: 04-Sep-23 Owners Group Resolution:
Approved TSTF Review Information TSTF Received Date:
07-Sep-23 Date Distributed for Review 07-Sep-23 TSTF Comments:
(No Comments)
Date: 29-Sep-23 TSTF Resolution:
Approved SR 3.4.14.1 NUREG(s)- 1430 1431 1432 Only RCS PIV Leakage SR 3.4.14.1 Bases NUREG(s)- 1430 1431 1432 Only RCS PIV Leakage SR 3.4.5.1 NUREG(s)- 1433 Only RCS PIV Leakage SR 3.4.5.1 Bases NUREG(s)- 1433 Only RCS PIV Leakage SR 3.4.6.1 NUREG(s)- 1434 Only RCS PIV Leakage 02-Oct-23 Copyright(C) 2023, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.
DRAFT
TSTF-600, Rev. 0 PWROG-18, Rev. 0 SR 3.4.6.1 Bases NUREG(s)- 1434 Only RCS PIV Leakage SR 3.4.15.1 NUREG(s)- 2194 Only RCS PIV Leakage SR 3.4.15.1 Bases NUREG(s)- 2194 Only RCS PIV Leakage 02-Oct-23 Copyright(C) 2023, EXCEL Services Corporation. Use by EXCEL Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.
DRAFT
TSTF-600, Rev. 0 Page 1
- 1.
SUMMARY
DESCRIPTION The proposed change revises the Surveillance Requirement (SR) to perform Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) leakage testing to eliminate any fixed or event-driven Frequencies and only reference the Inservice Testing Program (IST Program) for the Frequency. The proposed change affects the Standard Technical Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, NUREG-1434, and NUREG-21941.
- 2.
DETAILED DESCRIPTION 2.1. System Design and Operation RCS PIVs are any two normally closed valves in series within the reactor coolant pressure boundary (RCPB) that separate the high pressure RCS from an attached low pressure system, such as the Residual Heat Removal System and the low pressure Emergency Core Cooling System. The RCS PIVs are required by 10 CFR 50.55a to be leak tested in accordance with the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code). The number, design, and function of the RCS PIVs is plant-specific. The RCS PIVs are described in the plant's Updated Final Safety Analysis Report (UFSAR) and IST Program documentation.
The RCS PIV Leakage Limiting Condition for Operation (LCO) limits the leakage through the RCS PIVs to amounts that do not compromise safety. The RCS PIV leakage limit applies to each valve in the series and is specified in the Technical Specifications (TS) and the ASME OM Code. Any leakage through both in series RCS PIVs in a line is included in "identified leakage,"
and is limited by the TS LCO on "RCS Operational LEAKAGE."
2.2. Background On February 23, 1980, the NRC issued Generic Letter (GL) 80-14, "LWR Primary Coolant System Pressure Isolation Valves." The GL stated that the 1975 "Reactor Safety Study" (WASH-1400) identified an intersystem Loss of Coolant Accident (LOCA) as a significant contributor to the risk of Pressurized Water Reactor (PWR) core melt accidents. The study examined the configuration of in-series check valves acting as RCS PIVs with and without an in-series Motor Operated Valve (MOV) and concluded that a failure of these valves could lead to overpressurization and rupture of the connected low pressure piping. The GL stated that the probability of such a failure could be reduced by periodic IST leakage testing on each valve every time the plant is shutdown and each time the check valves are moved from the fully closed 1 NUREG-1430 provides the STS for the Babcock & Wilcox plant designs.
NUREG-1431 provides the STS for the Westinghouse plant designs.
NUREG-1432 provides the STS for the Combustion Engineering plant designs.
NUREG-1433 provides the STS for the BWR/4 plant designs, but is also representative of the BWR/2, BWR/3, and, in this case, of the BWR/5 plant design.
NUREG-1434 provides the STS for the BWR/6 plant designs, but is also representative in some cases of the BWR/5 plant design.
NUREG-2194 provides the STS for the Westinghouse AP1000 plant design.
DRAFT
TSTF-600, Rev. 0 Page 2 position, as well as other monitoring methods. The GL required each licensee to respond within 20 days in accordance with 10 CFR 50.54(f) and 1) describe the plant-specific valve configurations and whether a configuration of concern exists, 2) if a configuration of concern exists, what periodic or surveillance tests are performed to ensure integrity, and 3) if a configuration of concern exists, whether plant procedures should be revised or plant modification should be made to increase reliability.
After reviewing the licensee's responses, the NRC issued orders to those licensees with the RCS PIV configurations of concern. The order immediately incorporated provided TS on RCS PIVs into the plant's TS. The provided TS required periodic leakage rate testing prior to entering the operating mode after the plant was placed in a cold shutdown condition for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if testing had not been accomplished in the preceding 9 months and each time the RCS PIV may have been moved from the fully closed position. These testing frequencies are still used in the PWR STS, i.e., NUREG-1430, NUREG-1431, and NUREG-1432. The RCS PIV configurations of concern did not appear in the Boiling Water Reactor (BWR) plant designs and the event-based testing frequencies were not included in the BWR STS, NUREG-1433 and NUREG-1434.
2.3. Current Technical Specifications Requirements NUREG-1430, Specification 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage,"
SR 3.4.14.1, states:
NOTES-----------------------------
- 1. Not required to be performed in MODES 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the DHR flow path when in the DHR mode of operation.
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure
[2215] psia and [2255] psia.
[ In accordance with the INSERVICE TESTING PROGRAM OR
[ [18] months]
OR DRAFT
TSTF-600, Rev. 0 Page 3 In accordance with the Surveillance Frequency Control Program ]
AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND
[ Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve ]
NUREG-1431, Specification 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage,"
SR 3.4.14.1, states:
NOTES-----------------------------
- 1. Not required to be performed in MODES 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a In accordance with the DRAFT
TSTF-600, Rev. 0 Page 4 NUREG-1432, Specification 3.4.14, "RCS Pressure Isolation Valve (PIV) Leakage,"
SR 3.4.14.1, states:
NOTES-----------------------------
- 1. Not required to be performed in MODES 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the SDC flow path when in the shutdown cooling mode of operation.
maximum of 5 gpm at an RCS pressure
[2215] psig and [2255] psig.
INSERVICE TESTING PROGRAM, and
[ [18] months OR In accordance with the Surveillance Frequency Control Program ]
AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve DRAFT
TSTF-600, Rev. 0 Page 5
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure
[2215] psia and [2255] psia.
In accordance with the INSERVICE TESTING PROGRAM, and
[ [18] months OR In accordance with the Surveillance Frequency Control Program ]
AND Prior to entering MODE 2 determine the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve DRAFT
TSTF-600, Rev. 0 Page 6 NUREG-1433, Specification 3.4.5, "RCS Pressure Isolation Valve (PIV) Leakage," SR 3.4.5.1, states:
NOTE------------------------------
Not required to be performed in MODE 3.
Verify equivalent leakage of each RCS PIV is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm, at an RCS pressure [ ] and
[ ] psig.
[ In accordance with the INSERVICE TESTING PROGRAM OR
[ [18] months]
OR In accordance with the Surveillance Frequency Control Program ]
NUREG-1434, Specification 3.4.5, "RCS Pressure Isolation Valve (PIV) Leakage," SR 3.4.6.1, states:
NOTE------------------------------
Not required to be performed in MODE 3.
Verify equivalent leakage of each RCS PIV is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm, at an RCS pressure [ ] and
[ ] psig.
[ In accordance with the INSERVICE TESTING PROGRAM OR
[ [18] months]
OR In accordance with the Surveillance DRAFT
TSTF-600, Rev. 0 Page 7 Frequency Control Program ]
NUREG-2194, Specification 3.4.15, "RCS Pressure Isolation Valve (PIV) Integrity,"
SR 3.4.15.1, states:
SR 3.4.15.1 Verify leakage of each RCS PIV is equivalent to 0.5 gpm per nominal inch valve size up to a maximum of 5 gpm at an RCS pressure 2215 and 2255 psig.
24 months 2.4. Reason for the Proposed Change The RCS PIV leakage testing required by the STS is also required by the ASME OM Code as implemented in a site's IST Program. However, NUREG-1430, NUREG-1431, and NUREG-1432 require more frequent testing than is required by the ASME OM Code. The proposed change would align the STS testing frequency with the requirements of the ASME OM Code and eliminate unnecessarily frequent testing which could potentially lower outage dose and reduce outage time.
The proposed change also provides the opportunity for licensees to take advantage of industry experience by removing conflicts between their TS and the ASME OM Code. For example, Revision 4 of Regulatory Guide 1.192, endorses ASME OM Code Case OMN-23, "Alternative Rules for Testing Pressure Isolation Valves," with no conditions. This Code Case provides an alternative to the fixed the 2-year leakage rate test frequency specified by ASME OM Code Section ISTC-3630(a) and permits the implementation of a condition monitoring program for RCS PIVs. The Code Case does not replace or exclude any test method requirement specified in ISTC-3630, but does allow for the possibility of 24-month interval extensions, not to exceed a maximum interval of 6 years, dependent on analysis of tests results and maintenance history of the RCS PIVs. The existing STS testing requirements restrict the ability to implement the condition monitoring program because of the refueling interval and event-driven SR Frequencies. The proposed change does not include permission to use Code Case OMN-23. The Code Case describes its applicability. Other plants may need to request permission to use the Code Case.
NUREG-2194 (AP1000 plants), TS 3.4.15, "RCS Pressure Isolation Valve (PIV) Integrity,"
requires verification of RCS PIV leakage every 24 months with no event-driven Frequencies.
The Bases state that the 24-month frequency is based on the ASME OM Code, and is consistent with the testing Frequency in ASME OM Code Section ISTC 3630(a). The AP1000 SR Frequency is revised to be in accordance with the IST Program for the same reasons given above.
NUREG-1433 and NUREG-1434 (BWR plants) require verification of RCS PIV leakage in accordance with the IST Program or at a fixed Frequency or in accordance with the Surveillance Frequency Control Program (SFCP). There are no testing frequencies related to shutdown DRAFT
TSTF-600, Rev. 0 Page 8 conditions or valve actuation. However, all BWR plants with a PIV TS have a frequency that only references the IST Program. The traveler will revise the STS SR Frequency to be in accordance with the IST Program in order to make the BWR STS consistent with the BWR plant TS.
2.5. Description of the Proposed Change The Frequency for NUREG-1430, NUREG-1431, and NUREG-1432, SR 3.4.14.1, is revised to state, "In accordance with the INSERVICE TESTING PROGRAM."
The Frequency for NUREG-1433, SR 3.4.5.1, and for NUREG-1434, SR 3.4.6.1, is revised to state, "In accordance with the INSERVICE TESTING PROGRAM."
The Frequency for NUREG-2194, SR 3.4.15.1, is revised to state, "In accordance with the Inservice Testing Program." NUREG-2194 has not incorporated TSTF-545, Revision 3, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," which eliminated the TS Section 5.5, "Inservice Testing Program," and added a defined term with the same name.
Only the SR Frequency is revised. The proposed change does not add or remove any RCS PIVs from the plant's TS or ASME OM Code requirements. The proposed change does not alter the method of testing, the SR acceptance criteria, or any associated SR Notes. The proposed change does not change the RCS PIV testing frequency required by the ASME OM Code (typically 24 months).
The SR Bases are revised to reflect the changes to the SR Frequency.
A model application is attached. The model may be used by licensees desiring to adopt the traveler following NRC approval.
- 3.
TECHNICAL EVALUATION The proposed change makes three changes to the RCS PIV leakage testing Frequency:
- Elimination of a Frequency based on the SFCP or in the case of NUREG-2194, a fixed Frequency;
- Elimination of a Frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve; and
- Elimination of a Frequency of 9 months prior to entering MODE 2 if the unit has been in Mode 5 for 7 days or more.
Each of these changes are evaluated below.
DRAFT
TSTF-600, Rev. 0 Page 9 Testing in Accordance with the Surveillance Frequency Control Program or on a Fixed Frequency Under the SFCP, changes to the Frequencies must be made in accordance with NEI 04-10, Revision 1, "Risk-Informed Method for Control of Surveillance Frequencies." NEI 04-10, Step 7, requires identification of qualitative considerations that must be addressed, such as test intervals specified in applicable industry codes and standards, e.g., ASME, IEEE, etc. Because the RCS PIV testing frequency of 24 months is specified in the ASME OM Code, Section ISTC-3630, paragraph (a), the SR Frequency cannot be extended beyond 24 months under the SFCP without NRC approval of a relief request per 10 CFR 50.55a, paragraph (z), "Alternatives to codes and standards requirements." As a result, specifying the Frequency as "In accordance with the Surveillance Frequency Control Program," or as 24 months, is unnecessary, as the ASME OM Code and 10 CFR 50.55a are the controlling requirements. Changing the Frequency to be in accordance with the IST Program has no practical impact on the performance frequency of the SR and is equivalent to the current SFCP or fixed 24-month Frequency.
Testing Within 24 Hours of Valve Actuation Requiring an RCS PIV leakage test within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation is unnecessary.
The ASME OM Code requires more appropriate tests on the RCS PIVs, such as exercise testing per Code Subsection ISTC-3520, position indication verification per Subsection ISTC-3700, and testing after replacement, repair, or maintenance per Subsection ISTC-3310. These tests provide an acceptable method of determining the capability of the valves to transition from open to closed to perform their pressure isolation function without requiring a leakage test. The capability of the valves to transition from open to closed provides assurance that the valves can perform their pressure isolation function after being actuated and performance of an additional leak rate test is not needed. In removing the Frequency requiring performance of leakage testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation, the TS will instead require leakage test at a Frequency in accordance with the IST Program, which reinforces the established requirements of the OM Code that are endorsed by the NRC and incorporated by reference in 10 CFR 50.55a(a)(1)(iv).
The testing requirements contained within the OM Code are intended to assess the operational readiness of the stated components. Therefore, leakage testing of the RCS PIVs at the frequency established by the IST Program is satisfactory for determining valve integrity, particularly as it relates to operational readiness.
Testing Every 9 Months NUREG-1430, NUREG-1431, and NUREG-1432 require RCS PIV testing every 9 months with the caveat that the test is only required if plant conditions (Mode 5) and outage length (7 days) permit the performance of the testing.
The proposed change would remove this overly restrictive SR Frequency. Despite the current reliance on the SFCP and/or IST Program to establish the associated Frequency for these surveillances, there remains a requirement that the surveillance be performed prior to entering Mode 2 whenever the plant has been in cold shutdown for 7 days or more and if leakage testing has not been performed in the previous 9 months. This additional Frequency requirement effectively restricts the ability of the SFCP to extend frequencies beyond a single fuel cycle (i.e.,
DRAFT
TSTF-600, Rev. 0 Page 10 18 or 24 months). In removing the 9-month Frequency, the TS will instead require leakage test at a Frequency in accordance with the IST Program, which reinforces the established requirements of the OM Code that are endorsed by the NRC and incorporated by reference in 10 CFR 50.55a(a)(1)(iv). The testing requirements contained within the OM Code are intended to assess the operational readiness of the stated components. Therefore, leakage testing of the RCS PIVs at the frequency established by the IST Program is satisfactory for determining valve integrity, particularly as it relates to operational readiness.
As discussed in Section 2.2, this frequency was imposed on licensees by order in response to the findings of the 1975 "Reactor Safety Study," which identified potential intersystem LOCAs as a significant contributor to the risk of core melt. The state-of-the-art of risk assessment has progressed substantially since the 1975 "Reactor Safety Study." Intersystem LOCAs have been studied extensively by the industry and the NRC and the risk of an intersystem LOCA is no longer considered a significant contributor to the risk of core melt. As a result, the 9-month frequency for performing RCS PIV leakage testing is not necessary to reduce the probability of an intersystem LOCA to an acceptable level.
Other Considerations Paragraph (a) of 10 CFR 50.55a, "Documents approved for incorporation by reference,"
references the approved documents required to be followed for systems and components of nuclear power reactors. Specifically, paragraph (a)(1)(iv) references the ASME OM Code, which provides requirements for inservice testing of certain components in light-water nuclear power plants. The regulation in 10 CFR 50.55a(f)(5)(ii), "IST program update: Conflicting IST Code requirements with technical specifications," states in part, "If a revised inservice test program for a facility conflicts with the technical specifications for the facility, the licensee must apply to the Commission for amendment of the technical specifications to conform the technical specifications to the revised program." The current STS RCS PIV testing Frequencies are not in conflict with the IST Program, but are significantly more restrictive with regard to the testing frequency. Given that the clear intention of the regulation is that the IST Program requirements should be given preference over the TS requirements, it is appropriate to revise the SR Frequency to be consistent with the IST Program testing frequency.
Change to NUREG-1433 and NUREG-1434 The proposed change also updates the NUREG-1433 and NUREG-1434 RCS PIV leakage testing frequency as an administrative change. The BWR STS require verification of RCS PIV leakage in accordance with the IST Program and in accordance with the SFCP. However, all BWR plants with an RCS PIV TS have an SR Frequency that references the IST Program and does not reference the SFCP. Therefore, the STS frequency is revised to be consistent with the TS of the BWR plants.
- 4.
REGULATORY EVALUATION 4.1. Applicable Regulatory Requirements/Criteria The RCS PIVs are referred to in 10 CFR 50.2, "Definitions," under "Reactor coolant pressure boundary," and 10 CFR 50.55a(c), "Reactor coolant pressure boundary," as two normally closed DRAFT
TSTF-600, Rev. 0 Page 11 valves in series within the reactor coolant pressure boundary, which separate the high pressure RCS from attached lower pressure systems.
In accordance with 10 CFR 50.54, the applicable requirements of 10 CFR 50.55a are conditions of every nuclear power reactor operating license issued under 10 CFR Part 50. These requirements include IST of pumps and valves at nuclear power reactors pursuant to the ASME OM Code as specified in 10 CFR 50.55a(f). Paragraph (f) of 10 CFR 50.55a states in-part that systems and components of pressurized water-cooled nuclear power reactors must meet the requirements of the ASME Boiler and Pressure Vessel (BPV) Code and ASME OM Code. The ASME OM Code, a consensus standard incorporated by reference into 10 CFR 50.55a, was reviewed by NRC staff during the incorporation process to ensure the OM Code requirements were technically sufficient. The NRC staffs review for technical sufficiency found that the ASME OM Code IST program requirements were suitable for incorporation into the NRC's rules. Paragraph 50.55(a)(f)(5)(ii) of 10 CFR states in part that if a revised IST Program for a facility conflicts with the TS for the facility, the licensee must apply for an amendment of the TS to conform the TS to the revised program.
The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires:
Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.
Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.
Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.
Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications." The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.
DRAFT
TSTF-600, Rev. 0 Page 12 The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." The proposed traveler revises the Bases to be consistent with the Technical Specifications, and therefore, is in compliance with 10 CFR 50.36(a)(1).
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.
4.2. Precedent On February 1, 2023, Duke Energy submitted a license amendment request (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23032A162) for Catawba Nuclear Station, McGuire Nuclear Station, Oconee Nuclear Station, H. B. Robinson Steam Electric Plant, and Shearon Harris Nuclear Power Plant. The amendment request proposed to revise the SR Frequency for RCS PIV leakage testing in the same manner that is proposed by this traveler and using similar justifications. The license amendment was approved on [DATE] (ADAMS MLXXXXXXXXX). The NRC's technical evaluation of the Duke Energy change is also applicable to the proposed traveler.
- 5.
REFERENCES None.
DRAFT The Duke LAR is close to approval.
The approval date and accession number will be added before the traveler is submitted.
TSTF-600, Rev. 0 Model Application DRAFT
TSTF-600, Rev. 0 Page 1
[DATE]
10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKET NO. PLANT NAME
[5X]-[xxx]
SUBJECT:
Application to Revise Technical Specifications to Adopt TSTF-600, "Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].
[LICENSEE] requests adoption of TSTF-600, "Revise the Reactor Coolant System (RCS)
Pressure Isolation Valve (PIV) Leakage Testing Frequency," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-600 revises the Surveillance Requirement (SR) to perform RCS PIV leakage testing to eliminate any fixed or event-driven Frequencies and only reference the Inservice Testing Program (IST Program) for the Frequency.
The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. Attachment 2 provides revised (clean) TS pages. Attachment 3 provides the existing TS Bases pages marked to show revised text associated with the proposed TS changes and is provided for information only.
[LICENSEE] requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of completion of the NRCs acceptance review. Once approved, the amendment shall be implemented within [90] days.
There are no regulatory commitments in this letter.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated [STATE] Official.
[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.
Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]
DRAFT
TSTF-600, Rev. 0 Page 2 If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].
Sincerely,
[Name, Title]
Enclosure:
Description and Assessment Attachments: 1.
Proposed Technical Specification Changes (Mark-Up)
- 2.
Revised Technical Specification Pages
- 3.
Proposed Technical Specification Bases Changes (Mark-Up) - For Information Only
[The attachments are to be provided by the licensee and are not included in the model application.]
cc:
NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact DRAFT
TSTF-600, Rev. 0 Page 3 ENCLOSURE DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
[LICENSEE] requests to adopt of TSTF-600, "Revise the Reactor Coolant System (RCS)
Pressure Isolation Valve (PIV) Leakage Testing Frequency," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-600 revises the Surveillance Requirement (SR) to perform RCS PIV leakage testing to eliminate any fixed or event-driven Frequencies and only reference the Inservice Testing Program (IST Program) for the Frequency.
2.0 ASSESSMENT
2.1 Applicability of Safety Evaluation
[LICENSEE] has reviewed the safety evaluation for TSTF-600 provided to the Technical Specifications Task Force in a letter dated [DATE]. This review included the NRC staffs evaluation, as well as the information provided in TSTF-600. [LICENSEE] has concluded that the justifications presented in TSTF-600 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS.
2.2 Variations
[LICENSEE is not proposing any variations from the TS changes described in TSTF-600 or the applicable parts of the NRC staffs safety evaluation.] [LICENSEE is proposing the following variations from the TS changes described in TSTF-600 or the applicable parts of the NRC staffs safety evaluation:]
[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-600 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-600 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-600 to the [PLANT] TS.]
[The [PLANT] TS contain requirements that differ from the STS on which TSTF-600 was based but are encompassed by the TSTF-600 justification. (Describe the differences)]
[The [PLANT] TS do not include the changes in TSTF-545, "TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing." As a result, the
[PLANT] TS include a TS Section [5.5], "Inservice Testing Program," and do not include a defined term, "INSERVICE TESTING PROGRAM." Therefore, the proposed SR Frequency does not use a capitalized defined term.
[The [PLANT] TS are not based on the standard TS on which TSTF-600 is based. (Describe the differences. For example, changes to SR 4.0.5, SRs that reference the IST or 4.0.5, and SRs that contain requirements that are in STS programs.)]
DRAFT
TSTF-600, Rev. 0 Page 4
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Analysis
[LICENSEE] requests adoption of TSTF-600, "Revise the Reactor Coolant System (RCS)
Pressure Isolation Valve (PIV) Leakage Testing Frequency," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] Technical Specifications (TS). TSTF-600 revises the Surveillance Requirement (SR) to perform RCS PIV leakage testing to eliminate any fixed or event-driven Frequencies and only reference the Inservice Testing Program (IST Program) for the Frequency.
[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
- 1.
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change revises the SR to perform RCS PIV leakage testing to eliminate any fixed or event-driven Frequencies and only reference the IST Program for the Frequency.
Performance of the RCS PIV leakage testing is not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not significantly increased. The RCS PIVs for which the Surveillance Frequencies are revised are still required to be operable, meet the acceptance criteria for the SRs, and be capable of performing any mitigative function assumed in the accident analysis. The proposed test frequency has been endorsed in the American Society of Mechanical Engineers (ASME) Operations and Maintenance Code for Nuclear Power Plants, and in NRC regulation 10 CFR 50.55a. As a result, the consequences of any accident previously evaluated are not significantly increased.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The proposed change revises the SR to perform RCS PIV leakage testing to eliminate any fixed or event-driven Frequencies and only reference the IST Program for the Frequency.
No new or different accidents result from utilizing the proposed change. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the changes do not impose any new or different requirements on the affected components. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions.
DRAFT
TSTF-600, Rev. 0 Page 5 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change revises the SR to perform RCS PIV leakage testing to eliminate any fixed or event-driven Frequencies and only reference the IST Program for the Frequency.
The proposed change does not adversely affect existing plant safety margins, or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, [LICENSEE] concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
4.0 ENVIRONMENTAL CONSIDERATION
A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
DRAFT
TSTF-600, Rev. 0 Technical Specifications Changes DRAFT
RCS PIV Leakage 3.4.14 Babcock & Wilcox STS 3.4.14-3 Rev. 5.0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1
NOTES-----------------------------
- 1. Not required to be performed in MODES 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the DHR flow path when in the DHR mode of operation.
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure
[2215] psia and [2255] psia.
[ In accordance with the INSERVICE TESTING PROGRAM OR
[ [18] months]
OR In accordance with the Surveillance Frequency Control Program ]
AND TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage 3.4.14 Babcock & Wilcox STS 3.4.14-4 Rev. 5.0 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND
[ Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve ]
NOTE------------------------------
[ Not required to be met when the DHR System autoclosure interlock is disabled in accordance with LCO 3.4.12.
Verify DHR System autoclosure interlock prevents the valves from being opened with a simulated or actual RCS pressure signal [425] psig.
[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Babcock & Wilcox STS B 3.4.14-5 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)
For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.
Testing is to be performed every 9 months, but may be extended, if the plant does not go into MODE 5 for at least 7 days.
REVIEWERS NOTE-----------------------------------
If the testing is within the scope of the licensee's INSERVICE TESTING PROGRAM, the Frequency "In accordance with the INSERVICE TESTING PROGRAM" should be used. Otherwise, the periodic Frequency of [18] months or the reference to the Surveillance Frequency Control Program should be used.
[ The [18 month] Frequency is established by consistent with 10 CFR 50.55a(g) (Ref. 8) and as contained in the INSERVICE TESTING PROGRAM, is within frequency allowed by the American Society of Mechanical Engineers (ASME) OM Code (Ref. 7), and is based on the need to perform such surveillances under conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the plant at power.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
[ In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the valve has been reseated. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable and practical time limit for performing this test after opening or reseating a valve. ]
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Babcock & Wilcox STS B 3.4.14-6 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)
The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.
Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complimentary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the DHR System when the DHR System is aligned to the RCS in the decay heat removal mode of operation. PIVs contained in the DHR flow path must be leakage rate tested after DHR is secured and stable unit conditions and the necessary differential pressures are established.
REVIEWERS NOTE-----------------------------------
The "24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..." Frequency of performance for Surveillance Requirement 3.4.14.1 is not required for B&W Owner's Group plants licensed prior to 1980. These plants were licensed prior to the NRC establishing formal Technical Specification controls for pressure isolation valves. Subsequently, these earlier plants had their licenses modified by NRC Order to require certain PIV testing Frequencies (excluding the "24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..." Frequency) be included in that plant's Technical Specifications. Based upon the information available to the Staff at the time, the content of those Orders was considered acceptable. Since 1980, the NRC Staff has determined an additional PIV leakage rate determination is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following actuation of the valve and flow through the valve. This is necessary in order to ensure the PIV's ability to support the integrity of the reactor coolant pressure boundary.
The Revised Standard Technical Specifications include the "24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..."
Frequency to reflect current NRC Staff position on the need to include this test requirement within Technical Specifications.
[ SR 3.4.14.2 and SR 3.4.14.3 Verifying that the DHR autoclosure interlocks are OPERABLE ensures that RCS pressure will not pressurize the DHR system beyond 125% of its design pressure of [600] psig. The interlock setpoint that prevents the valves from being opened is set so the actual RCS pressure must be
< [425] psig to open the valves. This setpoint ensures the DHR design pressure will not be exceeded and the DHR relief valves will not lift. [ The 18 month Frequency is based on the need to perform this Surveillance TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Babcock & Wilcox STS B 3.4.14-7 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued) under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance was performed with the reactor at power. The 18 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
These SRs are modified by Notes allowing the DHR autoclosure function to be disabled when using the DHR System suction relief valve for cold overpressure protection in accordance with LCO 3.4.12. ]
REFERENCES
- 1.
- 2.
10 CFR 55a(c).
- 3.
10 CFR 50, Appendix A, Section V, GDC 55.
- 4.
NUREG-75/014, Appendix V, October 1975.
- 5.
NUREG-0677, NRC, May 1980.
- 6.
[Document containing list of PIVs.]
- 7.
ASME OM Code, "Code for Operation and Maintenance of Nuclear Power Plants."ASME Code for Operation and Maintenance of Nuclear Power Plants.
- 8.
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage 3.4.14 Westinghouse STS 3.4.14-3 Rev. 5.0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1
NOTES-----------------------------
- 1. Not required to be performed in MODES 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure
[2215] psig and [2255] psig.
In accordance with the INSERVICE TESTING PROGRAM, and
[ [18] months OR In accordance with the Surveillance Frequency Control Program ]
AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage 3.4.14 Westinghouse STS 3.4.14-4 Rev. 5.0 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve SR 3.4.14.2
NOTE------------------------------
[ Not required to be met when the RHR System autoclosure interlock is disabled in accordance with SR 3.4.12.7.
Verify RHR System autoclosure interlock prevents the valves from being opened with a simulated or actual RCS pressure signal [425] psig.
[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]
NOTE------------------------------
[ Not required to be met when the RHR System autoclosure interlock is disabled in accordance with SR 3.4.12.7.
Verify RHR System autoclosure interlock causes the valves to close automatically with a simulated or actual RCS pressure signal [600] psig.
[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Westinghouse STS B 3.4.14-5 Rev. 5.0 BASES ACTIONS (continued)
Required Action B.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.
However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.
The allowed Completion Times are reasonable based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
C.1 The inoperability of the RHR autoclosure interlock renders the RHR suction isolation valves incapable of isolating in response to a high pressure condition and preventing inadvertent opening of the valves at RCS pressures in excess of the RHR systems design pressure. If the RHR autoclosure interlock is inoperable, operation may continue as long as the affected RHR suction penetration is closed by at least one closed manual or deactivated automatic valve within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This Action accomplishes the purpose of the autoclosure function.
SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required Action A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition.
For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Westinghouse STS B 3.4.14-6 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)
Testing is to be performed every [9] months, but may be extended, if the plant does not go into MODE 5 for at least 7 days. [ The [18 month]
Frequency is established by consistent with 10 CFR 50.55a(g) (Ref. 9) and the INSERVICE TESTING PROGRAM, is within frequency allowed by the American Society of Mechanical Engineers (ASME) OM Code (Ref. 8), and is based on the need to perform such surveillances under the conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the valve has been reseated. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable and practical time limit for performing this test after opening or reseating a valve.
The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.
Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complementary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the RHR System when the RHR System is aligned to the RCS in the shutdown cooling mode of operation. PIVs contained in the RHR shutdown cooling flow path must be leakage rate tested after RHR is secured and stable unit conditions and the necessary differential pressures are established.
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Westinghouse STS B 3.4.14-7 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)
[ SR 3.4.14.2 and SR 3.4.14.3 Verifying that the RHR autoclosure interlocks are OPERABLE ensures that RCS pressure will not pressurize the RHR system beyond 125% of its design pressure of [600] psig. The interlock setpoint that prevents the valves from being opened is set so the actual RCS pressure must be
< [425] psig to open the valves. This setpoint ensures the RHR design pressure will not be exceeded and the RHR relief valves will not lift. [ The
[18] month Frequency is based on the need to perform the Surveillance under conditions that apply during a plant outage. The [18] month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
These SRs are modified by Notes allowing the RHR autoclosure function to be disabled when using the RHR System suction relief valves for cold overpressure protection in accordance with SR 3.4.12.7. ]
REFERENCES
- 1.
- 2.
- 3.
10 CFR 50, Appendix A, Section V, GDC 55.
- 4.
WASH-1400 (NUREG-75/014), Appendix V, October 1975.
- 5.
NUREG-0677, May 1980.
[ 6. Document containing list of PIVs. ]
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Westinghouse STS B 3.4.14-8 Rev. 5.0 BASES REFERENCES (continued)
- 7.
WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.
- 8.
ASME OM Code, "Code for Operation and Maintenance of Nuclear Power Plants."ASME Code for Operation and Maintenance of Nuclear Power Plants.
- 9.
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage 3.4.14 Combustion Engineering STS 3.4.14-3 Rev. 5.0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1
NOTES-----------------------------
- 1. Not required to be performed in MODES 3 and 4.
- 2. Not required to be performed on the RCS PIVs located in the SDC flow path when in the shutdown cooling mode of operation.
- 3. RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure
[2215] psia and [2255] psia.
In accordance with the INSERVICE TESTING PROGRAM, and
[ [18] months OR In accordance with the Surveillance Frequency Control Program ]
AND Prior to entering MODE 2 determine the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months AND TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage 3.4.14 Combustion Engineering STS 3.4.14-4 Rev. 5.0 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation due to automatic or manual action or flow through the valve SR 3.4.14.2
NOTE------------------------------
[ Not required to be met when the SDC System autoclosure interlock is disabled in accordance with SR 3.4.12.7.
Verify SDC System autoclosure interlock prevents the valves from being opened with a simulated or actual RCS pressure signal [425] psig.
[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]
NOTE------------------------------
[ Not required to be met when the SDC System autoclosure interlock is disabled in accordance with SR 3.4.12.7.
Verify SDC System autoclosure interlock causes the valves to close automatically with a simulated or actual RCS pressure signal [600] psig.
[ [18] months OR In accordance with the Surveillance Frequency Control Program ] ]
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Combustion Engineering STS B 3.4.14-5 Rev. 5.0 BASES SURVEILLANCE SR 3.4.14.1 REQUIREMENTS Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 or A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition.
For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.
Testing is to be performed every 9 months, but may be extended if the plant does not go into MODE 5 for at least 7 days. [ The [18] month Frequency is established by consistent with 10 CFR 50.55a(g) (Ref. 8) and the INSERVICE TESTING PROGRAM and is within frequency allowed by the American Society of Mechanical Engineers (ASME) OM Code (Ref. 7), and is based on the need to perform the Surveillance under conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
In addition, testing must be performed once after the valve has been opened by flow or exercised to ensure tight reseating. PIVs disturbed in the performance of this Surveillance should also be tested unless documentation shows that an infinite testing loop cannot practically be avoided. Testing must be performed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the valve has been reseated. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a reasonable and practical time limit for performing this test after opening or reseating a valve.
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Combustion Engineering STS B 3.4.14-6 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)
The leakage limit is to be met at the RCS pressure associated with MODES 1 and 2. This permits leakage testing at high differential pressures with stable conditions not possible in the MODES with lower pressures.
Entry into MODES 3 and 4 is allowed to establish the necessary differential pressures and stable conditions to allow for performance of this Surveillance. The Note that allows this provision is complimentary to the Frequency of prior to entry into MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months. In addition, this Surveillance is not required to be performed on the SDC System when the SDC System is aligned to the RCS in the shutdown cooling mode of operation. PIVs contained in the SDC shutdown cooling flow path must be leakage rate tested after SDC is secured and stable unit conditions and the necessary differential pressures are established.
SR 3.4.14.2 and SR 3.4.14.3 Verifying that the SDC autoclosure interlocks are OPERABLE ensures that RCS pressure will not pressurize the SDC system beyond 125% of its design pressure of [600] psig. The interlock setpoint that prevents the valves from being opened is set so the actual RCS pressure must be
< [425] psig to open the valves. This setpoint ensures the SDC design pressure will not be exceeded and the SDC relief valves will not lift. [ The 18 month Frequency is based on the need to perform these Surveillances under conditions that apply during a plant outage. The 18 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.14 Combustion Engineering STS B 3.4.14-7 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)
The SRs are modified by Notes allowing the SDC autoclosure function to be disabled when using the SDC System suction relief valves for cold overpressure protection in accordance with SR 3.4.12.7.
REFERENCES
- 1.
- 2.
- 3.
10 CFR 50, Appendix A, Section V, GDC 55.
- 4.
WASH-1400 (NUREG-75/014), Appendix V, October 1975.
- 5.
NUREG-0677, May 1980.
- 6. [ Document containing list of PIVs. ]
- 7.
ASME OM Code, "Code for Operation and Maintenance of Nuclear Power Plants."ASME Code for Operation and Maintenance of Nuclear Power Plants.
- 8.
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage 3.4.5 General Electric BWR/4 STS 3.4.5-2 Rev. 5.0 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME A.2 Isolate the high pressure portion of the affected system from the low pressure portion by use of a second closed manual, de-activated automatic, or check valve.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.5.1
NOTE------------------------------
Not required to be performed in MODE 3.
Verify equivalent leakage of each RCS PIV is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm, at an RCS pressure [ ] and
[ ] psig.
[ In accordance with the INSERVICE TESTING PROGRAM OR
[ [18] months]
OR In accordance with the Surveillance Frequency Control Program ]
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.5 General Electric BWR/4 STS B 3.4.5-4 Rev. 5.0 BASES ACTIONS (continued)
B.1 and B.2 If leakage cannot be reduced or the system isolated, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to MODE 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and MODE 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This action may reduce the leakage and also reduces the potential for a LOCA outside the containment. The Completion Times are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.4.5.1 REQUIREMENTS Performance of leakage testing on each RCS PIV is required to verify that leakage is below the specified limit and to identify each leaking valve.
The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition. For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.
REVIEWERS NOTE-----------------------------------
If the testing is within the scope of the licensee's INSERVICE TESTING PROGRAM, the Frequency "In accordance with the INSERVICE TESTING PROGRAM" should be used. Otherwise, the periodic Frequency of 18 months or the reference to the Surveillance Frequency Control Program should be used.
[ The 18 month Frequency is established required by 10 CFR 50.55a(g)
(Ref. 8) and the INSERVICE TESTING PROGRAM is within the American Society of Mechanical Engineers (ASME) OM Code (Ref.
4)ASME Code Frequency requirement and is based on the need to perform this Surveillance during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
OR The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.5 General Electric BWR/4 STS B 3.4.5-5 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
This SR is modified by a Note that states the leakage Surveillance is not required to be performed in MODE 3. Entry into MODE 3 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES.
REFERENCES
- 1.
- 2.
- 3.
10 CFR 50, Appendix A, GDC 55.
- 4.
ASME OM Code, "Code for Operation and Maintenance of Nuclear Power Plants." ASME Code for Operation and Maintenance of Nuclear Power Plants.
- 5.
NUREG-0677, May 1980.
- 6.
FSAR, Section [ ].
- 7.
NEDC-31339, November 1986.
- 8.
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage 3.4.6 General Electric BWR/6 STS 3.4.6-2 Rev. 5.0 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME A.2 Isolate the high pressure portion of the affected system from the low pressure portion by use of a second closed manual, deactivated automatic, or check valve.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND B.2 Be in MODE 4.
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.6.1
NOTE------------------------------
Not required to be performed in MODE 3.
Verify equivalent leakage of each RCS PIV is 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm, at an RCS pressure
[1040] psig and [1060] psig.
[ In accordance with INSERVICE TESTING PROGRAM OR
((18] months OR In accordance with the Surveillance Frequency Control Program ]
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.6 General Electric BWR/6 STS B 3.4.6-4 Rev. 5.0 BASES ACTIONS (continued) reduces the potential for a LOCA outside the containment. The Completion Times are reasonable, based on operating experience, to achieve the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.4.6.1 REQUIREMENTS Performance of leakage testing on each RCS PIV is required to verify that leakage is below the specified limit and to identify each leaking valve.
The leakage limit of 0.5 gpm per inch of nominal valve diameter up to 5 gpm maximum applies to each valve. Leakage testing requires a stable pressure condition. For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.
REVIEWERS NOTE-----------------------------------
If the testing is within the scope of the licensee's INSERVICE TESTING PROGRAM, the Frequency "In accordance with the INSERVICE TESTING PROGRAM" should be used. Otherwise, the periodic Frequency of 18 months or the reference to the Surveillance Frequency Control Program should be used.
[ The 18 month Frequency is established required by 10 CFR 50.55a(g)
(Ref. 8) and the American Society of Mechanical Engineers (ASME)
OM Code (Ref. 4)INSERVICE TESTING PROGRAM is within the ASME Code Frequency requirement and is based on the need to perform this Surveillance under the conditions that apply during an outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
TSTF-600, Rev. 0 DRAFT
RCS PIV Leakage B 3.4.6 General Electric BWR/6 STS B 3.4.6-5 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)
Therefore, thisThis SR is modified by a Note that states the leakage Surveillance is not required to be performed in MODE 3. Entry into MODE 3 is permitted for leakage testing at high differential pressures with stable conditions not possible in the lower MODES.
REFERENCES
- 1.
- 2.
- 3.
10 CFR 50, Appendix A, GDC 55.
- 4.
ASME OM Code, "Code for Operation and Maintenance of Nuclear Power Plants."ASME Code for Operation and Maintenance of Nuclear Power Plants.
- 5.
NUREG-0677, May 1980.
- 6.
FSAR, Section [ ].
- 7.
NEDC-31339, November 1986.
- 8.
TSTF-600, Rev. 0 DRAFT
RCS PIV Integrity 3.4.15 AP1000 STS 3.4.15-2 Rev. 0 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)
A.2 Verify a second OPERABLE PIV can meet the leakage limits. This valve is required to be a check valve, or a closed valve, if it isolates a line that penetrates containment.
72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> B. Required Action and associated Completion Time not met.
B.1 Be in MODE 3.
AND 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> B.2 Be in MODE 5.
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Verify leakage of each RCS PIV is equivalent to 0.5 gpm per nominal inch valve size up to a maximum of 5 gpm at an RCS pressure 2215 and 2255 psig.
In accordance with the Inservice Testing Program24 months TSTF-600, Rev. 0 DRAFT
RCS PIV Integrity B 3.4.15 AP1000 STS B 3.4.15-5 Rev. 0 BASES SURVEILLANCE REQUIREMENTS SR 3.4.15.1 Performance of leakage testing on each RCS PIV or isolation valve used to satisfy Required Action A.1 and Required Action A.2 is required to verify that leakage is below the specified limit and to identify each leaking valve. The leakage limit of 0.5 gpm per inch nominal valve size up to a minimum of 5 gpm applies to each valve. Leakage testing requires a stable pressure condition.
For the two PIVs in series, the leakage requirement applies to each valve individually and not to the combined leakage across both valves. If the PIVs are not individually leakage tested, one valve may have failed completely and not be detected if the other valve in series meets the leakage requirement. In this situation, the protection provided by redundant valves would be lost.
The Frequency is established by the ASME Codetesting Testing shall be performed every 24 months, a typical refueling cycle. The 24 month Frequency is consistent with 10 CFR 50.55a(g) (Ref. 4) as contained in the Inservice Testing Program and is within frequency allowed by the and the American Society of Mechanical Engineers (ASME) OM Code (Ref. 5).
REFERENCES
- 1.
- 2.
- 3.
10 CFR 50, Appendix A, Section V, GDC 55.
- 4.
- 5.
ASME OM Code, Code for Operation and Maintenance of Nuclear Power Plants.
TSTF-600, Rev. 0 DRAFT