ML20212P470

Proposed Tech Specs Allowing Entry Into Operational Conditions 1 & 2 W/O Performing Surveillance Requirement 4.1.3.1.4.a for Scram Discharge Vol Vents Provided Test Performed at Least Every 18 Months

ML20212P470
Person / Time
Site:	Grand Gulf
Issue date:	08/26/1986
From:	MISSISSIPPI POWER & LIGHT CO.
To:
Shared Package
ML20212P458	List: AECM-86-0238, Forwards Revised Application for Amend to License NPF-29, Allowing Entry Into Operational Conditions 1 & 2 W/O Performing Surveillance Requirement 4.1.3.1.4.a Provided Test Performed at Least Every 18 Months ML20212P464 ML20212P470
References
TAC-60587, TAC-60588, TAC-60589, TAC-60590, TAC-60591, TAC-60592, TAC-61782, NUDOCS 8609030149
Download: ML20212P470 (8)

Text

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REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) 4.1.3.1.4 The scram discharge volume shall be determined OPERABLE by demonstrating:

a.A The scram discharge volume drain and vent valves OPERABLE, when control rods are scram tested from a normal control rod configuration of less than or equal to 50% R00 DENSITY at least once ;.sr 18 months, by verifying that the drain and vent valves:

1. Close within 30 seconds after receipt'of a signal for control rods to scram, and -

2. Open when the scram signal is reset.

b. Proper level sensor response by performance of a CHANNEL FUNCTIONAL TEST of the scram discharge volume scram and control rod block level instrumentation at least once per 31 days.

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PDR ADOCK 05000416 P PDR

o Item 2 PS-86/03 Additional Submittal

SUBJECT:

Technical Specifications 3.5.1 and 4.5.1, pages 3/4 5-3 and 5-5 DISCUSSION: The proposed technical specification changes result from prior commitments made by Mississippi Power & Light (MP&L) to monitor and test the Automatic Depressurization System (ADS) related air system. These comitments were subsequently placed in Facility Operating License NPF-29 as operating license condition 2.C.(33)g with solutions to be provided to the Nuclear Regulatory Commission (NRC) prior to start-up following the first refueling outage.

JUSTIFICATION: In a letter to Mr. Harold R. Denton from L. F. Dale dated October 26, 1982 (AECM-82/0510), Mississippi Power & Light (MP&L) committed to perform an integrated leak test on the ADS air system every 18 months. This test is initiated by turning off the instrument air booster compressors and by venting the booster compressor discharge to atmosphere. The pressure decay rate in each of the two ADS air headers is monitored and an extrapolated seven-day air pressure is determined. The leakage test is considered successful if the air pressure after seven days (based on extrapolation from test data) is above 110 psig.

Tests have shown that with the ADS air system at 110 psig, each ADS valve'can Le actuated two times against 70% of drywell

~ design pressure.

This seven day test period is a recomendation from the General Electric "BWR Plant Requirement; Plant Air" document which is

.to be applied on an individual plant basis. It is.not a General Electric design requirement. However, the seven day pressure decay test is being placed in the technical specifications in order to demonstrate system conformance to these GE recommendations.

Instrumentation to be provided before startup following the first refueling outage to monitor ADS air receiver pressure is shown on the attached drawing to this proposed change. This instrumentation to monitor. ADS air receiver pressure will consist of a separate alarm and pressure indicator in the control room for each Division 1 and 2. MP&L committed to install instrumentation to monitor ADS air receiver pressure in a letter dated October 26, 1982 (AECM-82/0510). Environmental

. Qualification of pressure transmitters will be in accordance with 10CFR50.49. Design codes for installation will be in accordance with IEEE-323, 1974 and all applicable codes listed in the FSAR. The trip setpoint for the ADS air receiver pressure alarm is based on an analytical lower limit of 147 psig. The lower limit is determined by the minimum pressure required to provide two actuations for each ADS valve and then hold the ADS valves open for five days under the most limiting accident conditions (Letter from NRC to MP&L dated March 15, J19 MISC 86080802 - 1

1985). The seven day air supply is a measured capacity and serves to demonstrate the adequacy of the system under normal plant conditions. The successful completion of the seven day leakage testing ensures that the assumed leakage rate of 1 SCFH per valve, which is also the basis for the calculated five day supply, is a valid assumption. The upper limit for the alarm will be administratively controlled to ensure that it is below the ADS booster start signal trip setpoint currently set at a nominal 160 psig. To ensure that an alarm is generated well before the minimum required ADS air receiver pressure is reached, the nominal trip setpoint will be 2 150 psig. This nominal trip setpoint will be maintained to ensure that an alarm is not generated before the booster compressor starts. If an alarm is generated, operators will "ake appropriate action in accordance with alarm response instructions including declaring the ADS system inoperable if required by the technical specifications. These alarm response instructions will replace the operators Round Sheet instructions to read the pressure indication every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Surveillances will be added to the technical specifications for the accumulator low pressure alarm channels. These changes will include a CHANNEL CALIBRATION to be performed once per 18 months and a CHANNEL FUNCTIONAL TEST to be performed once per 31 days. These surveillance requirements are being added to conform with the GE standard technical specification. In addition to the surveillance requirements, an action statement will be added as the appropriate action to take for an inoperable instrumentation channel. This action statement will require that local monitoring of ADS accumulator pressure be performed at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when an ADS low pressure alarm instrumentation channel (s) is inoperable. In addition, .

the inoperable channel (s) must be restored to operable status within 7 days. Otherwise, the ADS valves will be declared inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance is adequate to detect problems with the air system since the present surveillance interval is once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (without alarm instrumentation installed) and has been demonstrated to be adequate. The 7 day requirement allows sufficient time to effect repairs while assuring that instrumentation is restored to operable status in an appropriate time frame.

In addition to the proposed technical specification changes, MP&L will implement administrative procedures to test the instrument air quality to ADS. A sample of instrument air will be taken every 6 months to ensure that the proper air quality is maintained. These air samples will be analyzed for moisture content, particle size, and oil content and will be required to meet the General Electric design (22A2738, Rev. 3) requirements for ADS system safety-related components. This General Electric designspecificationrequiresthattheADSairsgpplybe oil-free ( <. 1 ppm), dried to a dew point of - 40 F at 100 psig, and filtered to 50 microns.

J19 MISC 86080802 - 2

p,*

The proposed' administrative procedure will require that the instrument air quality be verified-to be within the. required' limits at least once per every 6 months. The 6 month test interval will allow for comparisons of test' data for determining if system degradation is taking place. In the event the instrument air quality fails to meet the design requirements.

. .an engineering evaluation will be performed within 7-days.

MP&L at present contracts to an off-site laboratory the sampling of ADS instrument air quality. The laboratory supplies the evacuated cylinders used to collect the air sample. These cylinders must be requested from the laboratory just prior to collecting a sample. Once the sample is drawn, the cylinder is shipped back to the laboratory for analysis. Total analysis time from the time the cylinder is requested until results are received from the sample is approximately 3 to 4 weeks. Based on this time period, MP&L believes that a testing interval of less than six months would place undue constraints on the operation of the plant. The six month testing interval will allow for the comparison of previous tests and the early detection of. system degradation.

SIGNIFICANT HAZARDS' CONSIDERATIONS:

g Thel proposed amendment would add a 7 day extrapolated pressure decay test on the ADS air system to Technical Specification 4.5.1. The proposed amendment would also add control room indication and surveillances of the ADS air receiver pressure.

These changes are being made to meet prior commitments and to satisfy the provisions of operating license condition 2.C.(33)g before startup following the first refueling outage.

The-18 month leak test and CHANNEL CALIBRATION along with the 31 day CHANNEL FUNCTIONAL TEST will be performed to help ensure proper functioning of the safety related components in the ADS air system. The implementation of these test procedures'and the addition of instrumentation in the' control room to monitor ADS air receiver pressure does not alter the evaluations of previous

-accidents. These new test requirements are in addition to and are more restrictive than present technical specification requirements. Therefore the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated because the change will' add improvements to the ADS air system which will result in direct notification of control room personnel to the loss of the ADS air supply. The addition of leak' testing will also help to ensure proper functioning of the ADS safety-related components. The possibility of a new or i different kind of accident will not be created by the performance of the 18 month leak test because this test will be conducted while the plant is in modes 4 & 5 and the ADS system is not required to be operable during these modes.

J19 MISC 86090802 - 3

Ts Itaposing the 18 month leak ' test, CHANNEL CALIBRATION, and the 31 day CHANNEL FUNCTIONAL TEST helps to further ensure that the ADS air system will perform its safety function thus there is no significant reduction in the margin of safety. The margin of: safety will.be increased by the addition of pressure indication and alarms in the control room by ensuring a faster operator response to loss of instrument' air.

Therefore, the proposed change involves no significant hazards considerations.

l 1

l 6

i J19 MISC 86080802 - 4

EMERGENCY CORE COOLING SYSTEMS  :

/

l LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

e. For ECCS divisions 1 and 2, provided that ECCS division 3 is OPERABLE and divisions 1 and 2 are otherwise OPERA 8LE:

1. With one of the above required ADS valves inoperable, restore the inoperable ADS valve to OPERA 8LE status within 14 days or be in at least HOT SHUT 00WN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to i 135 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2. With two or more of the above required AOS valves inoperable, be in at least HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and reduce reactor steam dome pressure to i 135 psig within the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

f. With an ECC'S discharge line " keep filled" pressure alarm instrumentation channel inoperable, perform Surveillance Requirement 4.5.1.a.1 at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

g. With an ECCS header delta P instrumentation channel inoperable, restore the inoperable channel to OPERABLE status with 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or determine ECCS header delta P. locally at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; otherwise declare the associated ECCS inoperable.

h. In the event an ECCS system is actuated and infects water into the Reactor Coolant System, a Special Report shall,be prepared and sub-mitted to the Commission pursuant to Specification 6.9.2 within 50 days describing the circumstances of the actuation and the total accumulated actuation cycles to date. The current value of the i useage factor for each affected safety injection nozzle shall be i

provided in this Special Report whenever its value exceeds 0.70.

j --

"Whenever two or more RHR subsystems are inoperable, if unable to attain COLD SHUTDOWN as required by this ACTION, maintain reactor coolant temperature as low as practical by use of alternate heat removal methods.

1. With an ADS ic e pressure alarm system instrumentation channel (s) '

inoperable, determine the associated ADS accumulator pressure locally at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; restore the inoperable channel (s) to OPERABLE status within 7 days; otherwise declare the associated ADS valves inoperable.

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EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2) Low pressure setpoint of the:

(a) LPCI A and B subsystem loop to be 1 38 psig.

(b) LPCI C subsystem loop and LPCS system to be 1 22 psig.

(c) HPCS system to be 1 18 psig, b) Header delta P instrumentation and verifying the setpoint of the HPCS system and LPCS system and LPCI subsystems to be 1.2 0.1 psid change from the normal indicated AP.

3.' Verifying that the suction for the HPCS system is automatically transferred from the condensate storage tank to the suppression pool on a condensate storage tank low water level signal and on a suppression pool high water level signal,

d. For the ADS at least once per 18 months by:

4 ba

1. Performing a system functional test which includes simulated e-automatic actuation of the system throughout its emergency '

operating sequence, but excluding actual valve actuation. ((

5. Manually opening each ADS valve when the reactor steam dome pressure is greater than or equal to 100 psig* and observing

]3 that either: 'l

-s a) The control valve or oypass valve position responds gg accordingly, or -

b) There is a corresponding change in the measured steam f

(g flow.

3. Performing an extrapolated pressure decay test on the ADS air system to demonstrate system pressure will be maintained for 7 days at a value Jk;110 psig without makeup air available.

4. Performing a CHANNEL CALIBRATION of the accumulator low pressure alarm channels and verifying an alarm setpoint of jt 150 psig on decreasing pressure.

e. For the ADS at least once per 31 days by performing a CHANNEL FUNCTIONAL TEST of the accumulator low pressure alarm channels.

The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure is ~

adequate to perform the test.

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