ML19332E100

Proposed Tech Specs Re Addition of Note to Applicability Statements of Tech Specs 3.7.1.2 Auxiliary Feedwater Sys & 3.7.1.6 Atmospheric Relief Valves to Allow Entry Into Mode 3 to Perform post-maint & post-mod Testing

ML19332E100
Person / Time
Site:	Seabrook
Issue date:	11/22/1989
From:	PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
Shared Package
ML19332D336	List: ML19332D335 ML19332E100
References
NUDOCS 8912060238
Download: ML19332E100 (7)

Text

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I PLANT SYSTEMS l

') ' TURBINE CYCLE t

AUXILIARY FEEDWATER SYSTEM l-LIMITING CON 0! TION FOR OPERATION 3.7.1.2 At least three independent steam generator auxiliary feedwater pumps and associated flow paths shall be OPERABLE with:  ;

a. One motor-driven emergency feedwater pump, and one startup i feedwater pump capable of being powered from an emergency bus and capable of being aligned to the. dedicated water volume in the condensate storage tank, and b.. One steam turbine-driven emergency feedwater pump capable of being }

. powered from an OPERABLE steam supply system.

APPLICABILITY: MODES 1, 2, and 3.* l ACTION:

a. With one auxiliary feedwater pump inoperable, restore the required auxiliary feedwater pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN  !

within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

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. b. With two emergency feedwater pumps inoperable, restore at least one ,

'- emergency feedwater pump to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and restore both emergency feedwater pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

L c. With' one emergency feedwater pump and the startup feedwater pump inoperable, restore both emergency feedwater pumps to OPERABLE status wii.hin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and all three pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT ,

SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

d. With three auxiliary feedwater pumps inoperable, immediately initiate corrective action to restore at least one auxiliary feedwater pump to OPERABLE status as soon as possible.

SURVEILLANCE REQUIREMENTS __

4.7.1.2.1 Each auxiliary feedwater pump shall be demonst' rated OPERABLE:

a. At least once per 31 days on a STAGGERED TEST BASIS by:

1) Verifying that the motor-driven emergency feedwater pump develops a discharge pressure of greater than or equal to 1460 psig at a flow of greater than or equal to 270 gpm;

• =t r e ir d ir, i de 3 triil initi criticclity is a; hie ed.

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INSERT A FOR T/S 3.7.1.2  ;

• Entry into this MODE is permitted to perform post-modification ,

or post-maintenance testing to verify the OPERABILITY of the i turbine. driven' emergency feedwater pump. ACTION requirernents  ;

shall not apply until OPERABILITY has been verified-. l l

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l PLANT SYSTEMS- *

D- TURBINE CYCLE l ATMOSPHERIC RELIEF VALVES  !

LINITING CONDITION FOR OPERATION l

3. 7.1. 6 At least four atmospheric relief valves and associated manual controls I including the safety-related gas supply systems shall be OPERABLE.

APPLICABILITY: MODES 1, 2, n ,

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-ACTION: 1 i a.

With one less than the required atmospheric relief valves OPERABLE, restore the required atmospheric relief valves to OPERABLE status within 7 days; or be in at least HOT STANDBY within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b.

With two less than the required atmospheric relief valves OPERABLE, restore .

at least three atmospheric relief valves to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least, HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. .

SURVEILLANCE REQUIREMENTS 4.7.1.6 Each atmospheric relief valve and associated manual controls including _

• the safety-related gas supply systems shall be demonstrated OPERABLE: .

a.

At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying that the nitrogen accumulator tank is at a pressure greater than or equal to 500 psig,

b. Prior to startup following any refueling shutdown or cold shutdown .

- of 30 days or longer, verify that all valves will open and close '

fully by operation of manual controls.

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• When steam generators are being used for decay heat removal.

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INSERT A FOR T/S 3.7.1.6  :

1. Entry.into this MODE is permitted to perform post-modification  ;

-or post-maintenance testing to verify the OPERABILITY of r components. ACTION requirements shall not apply until  !

OPERABILITY has been verified. ,

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New Hampshire Yankee  !

November 22, 1989 l ENCLOSURE 2 TO NYN-89150 Backaround .

The steam turbine-driven emergency feedwater (EFW) pump steam supply -

system and the atmospheric steam dump valves (ASDVs)'are being modified during the current outage at Seabrook Station. Prior to declaring these components operable following modification, testing is required. This testing requires plant conditions not attainable prior to entry into MODE 33 however, the Technical Specifications associated with these items (3.7.1.2 and 3.7.1.6) require these systems to be operable prior to entry into ,

MODE 3. ,

Descriotion of Prooosed Channess l To facilitate the required post-modification testing of these systems, as well as future post-modification and post-maintenance operability testing, New Hampshire Yankee (NHY) proposes to modify these Technical Specifications by adding a note to the Applicability section of these Technical Specifications to allow entry into MODE 3, prior to declaring the affected components operable, where the required conditions exist to perfonn the necessary testing.  :

Safety Evaluation of Proposed Channes New Hampshire Yankee has reviewed the proposed changes utilizing the criteria specified in 10 CFR 50.92 and has determined that the proposed change would not

1. Involve a significant increase in the probability of consequences of any accident previously evaluated. The change involves clarifications to the administrative rules concerning entry into MODE 4 or MODE 3 following a cold shutdown during which maintenance or modification work was performed on the turbine-driven EFW pump or the atmospheric steam dump valves. There are no physical changes to the facility. ,

The failure of an ASDVs to close is a condition analyzed in FSAR 15.1. Post maintenance / modification retests would normally involve an exercise test during which time there is a potentia!

for the valve to fail to close following an open stroke. The internal pilot arrangement and internal steam leakage characteristics of these valves make it necessary to perform retests at normal operating pressure and temperature (NOP/NOT) l with steam present rather than during cold plant conditions. This test would be performed while the plant is in a shutdown condition with all control rods inserted and suberiticality margin greater than or equal to the MODE 3 Technical Specification requirement.

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! New Hampshire Yankee  !

November 22, 1989 l.

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In addition, the routine surveillance test which would be used as the retest method for almost all maintenance / repair situations  :

involves stroking one ASDV at a time with the block valve closed.  !

[ This would eliminate the potential for any cooldown effect. I f l l The failure of the turbine-driven EFW pump to operate when  ;

required could involve a decrease in secondary heat removal b capability. However, the proposed change _ applies only to stable I

shutdown conditions where the two motor-driven AFW pumps, (the startup feed pump (SUFP) and the motor-driven EFW pump), are  !

0PERABLE and the plant is preparing for a startup rather than performing a cooldown under emergency conditions. j The proposed change will not increase the consequences of an I accident previously evaluated in the FSAR. The proposed change l applies to MODE 3 therefore the reactor will be suberitical under ,

the conditions stated above. These tests would not be performed j with steam generator tube leakage or primary / secondary coolant '

activities in excess of technical specification limits.

ASDV or turbine-driven EFW pump post maintenance / modification l retests involve brief time intervals in stable shutdown plant  !

conditions as described above. Multiple failures in both fuel integrity and primary to secondary boundary integrity (unrelated  :

to a failure in either the ASDV or turbine-driven EFW pump) would i have to occur to cause an increase in the dose consequences.

2. Create the possibility of a new or different kind of accident from ,

any previously evaluated. The proposed change does not alter any physical components and the failure of these components has been previously analyzed. The test methods used for the ASDVs will only involve the test of a single valve at a time. In the case of the turbine-driven EFW pump, the SUFP and the motor-driven EFW pump are required to be operable. .

The possibility of a malfunction of a different type than any previously evaluated in the FSAR will not be increased. The failure of an ASDV to open when demanded or fail to close when required are the worst case failure modes for these valves and have been previously evaluated.

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New Hampshire Yankee

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3. Involve a significant reduction in a margin of safety. The ,

,1 proposed changes apply to the administrative rules concerning  ;

entry into MODES 3 and 4 under conditions where the components involved are expected to be capable of operation but have not ,

undergone a retest to actually demonstrate OPERABILITY. The ASDvs are not specifically mentioned in the Technical

. Specification Bases. However their primary purpose.is to facilitate a controlled plant cooldown if the condenser is . tot  ;

available as a heat sink. The AFW pumps are mentioned in the bases for Technical Specification 3.7.1.2 as being required to support a cooldown of the reactor coolant system to less than 350 ,

degrees with a loss of all offsite power present.

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