ML20083M815

Proposed Tech Specs Re Extension of Surveillance Test Intervals for Esws to Support 24 Month Operating Cycles

ML20083M815
Person / Time
Site:	FitzPatrick
Issue date:	05/12/1995
From:	POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20083M811	List: ML20083M808 ML20083M815 ML20083N615
References
NUDOCS 9505220078
Download: ML20083M815 (11)

Text

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JAFNPP ' -

4.11 (Cont *d) -

! 3.11 (cont'd)

D. Emeroency Service Water System D. Emeroency Service Water System ,

1. Surveillance of the ESW system shall be performed as

1. To ensure adequste equipment and area cooling, both ESW follows:

systems shall be operable when the requirements of

014 specification 3.5.A and 3.5.B must be satisfied, except as itgm Frecuency 38 specified below in specification 3.11.D.2.

E a. Simulated Automatic Once every 24 months D@ Actuation Test Ku b. Flow Rate Test - Each Once/3 months o4 ESW pump shall deliver

@@ at least 1500 gpm to its

.,@$ respective loop. The pump g@N total developed head shall be u greater than or equal to the corresponding point on the pump curve, reduced by a maximum of 7% for the measured flow.

c. Pump Operability Once/ month

d. Motor Operated Once/ month Valves Amendment No. 74~,124,2M :

240

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O' JAFNPP 3.11 (cont'd) 4.11 (cont'd) .

e. ESW instrumentation check Once/ day ESW instrument channel calibration Once/3 months -

f.- Logic System ' Once every

2. From and after the time that one Emergency Service Functional Test 24 months Water System is made or found to be inoperable for any reason continued reactor operation is permissible for a 2. ESW will not be supplied to RBCLC system during -

period not to exceed 7 days, provided that: testing.

the operable Emergency Diesel Generator System is demonstrated to be operable immediately and daily thereafter; and, all Emergency Diesel Generator System emergency i loads are verified operable immediately and daily ~

thereafter.

3. If specification 3.11.D.2 cannot be met the reactor shall be placed in the cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

3. Not Used k

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. Amendment No. 24tr, .19"Z .

241 i

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' ATTACHMENT 11 to JPN-95-025 l

l Safety Evaluation For Proposed Changes to Technical Specification l Emergency Service Water System Surveillance Test intervals to Ac.commodate 24-MonibEperating Cycles (JPTS-95-001F)

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I New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR 59

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Attachment 11 to JPN-95-025  ;

Emergency Service Water System SAFETY EVALUATION Page 1 of 5 I. DESCBIPIlON OF THE PROPOSED CHANGES s

. 1. Page 240, Specification 4.11.D.1.a. change "Each operating cycle" to "Once every 24 months." The revised specification reads:

a. Simulated Once every ,

Automatic 24 months Actuation Test

2. Page 241, Specification 4.11.D.1.e, revise format of this specification as follows:

e. ESW Instrumentation check Once/ day ESW Instrument channel calibration Once/3 months  ;

3. Page 241, Specification 4.11.D.1.f, change "Once/each operating cycle" to "Once every 24 months." The revised specification reads:

f. Logic System Once every ,

Functional Test 24 months 1 l

11. T PUBROSE.OE EEEELQEOSED_ CHANGES This application for amendment proposes to extend the Emergency Service Water

. System (ESW) surveillance test intervals to accommodate a 24 month operating cycle.

The proposed change in test frequency is every 24 months. These changes are necessary to avoid an extended mid-cycle outage. These changes follow the guidance provided by Generic Letter 9104, " Changes in Technical Specification Surveillance l Intervals to Accommodate 24-Month Fuel Cycle,"(Reference 1). Extension of the l surveillance test intervals was evaluated for the FitzPatrick ESW system and the l results documented in Reference 2. l I

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Attachment 11 to JPN-95 025 Emergency Service Water System e SAFETY EVALUATION Page 2 of 5 Ill. SAFETY _llWLEUCATION OF THE P_ROPOSED3HANGES The service water system consists of three subsystems: the emergency service water system, the normal service water system, and the RHR service water system. The specific surveillances discussed in this amendment request are associated with the ESW system. The other two systems do not require surveillance test extensions to 24 months since there are no technical specification required once per cycle surveillance tests associated with these systems. (The monthly operability test of the RHR service water pumps and associated MOVs in Specification 4.5 B.1.c.1 is not impacted by this amendment request).

The ESW system is a safety related system providing heat removal for the emergency core cooling system (ECCS) components and other equipment essential to safe reactor shutdown. The system consists of two independent supply locps, each supplied by a 100% capacity, motor driven, vertical turbine pump. Each pump takes o suction from a separate location M the screenwell and discharges through independent strainers into separate supply headers. The system also includes five MOVs (two pump discharges, two bypass valves, and one cross-connect). Each train of the ESW  ;

system is required to supply raw water cooling to one train of the following safety

. related loads:

- Emergency Diesel Generator Jacket Water Heat Exchangers,

- Electric Bay Unit Coolers,

- Cable Tunnel /Switchgear Room Coolers,

- Control Room and Relay Room Air Handling Units, and

- Crescent Area Unit Coolers Normally, the ESW system is maintained in standby condition and operates automatically in response to an indicated loss of reactor building closed loop cooling water system or upon start of one or more emergency diesel generators.

The longer cycle length requires an extension to the ESW simulated automatic actuation test and logic system functional test. This surveillance test demonstrates that the reactor building closed loop cooling (RBCLC) pump discharge header pressure switches and ESW Lockout Matrix relays will cause ESW pumps to start and RBCLC and ESW motor operated valves to reposition to an ESW injection lineup. Ten surveillance test results were reviewed from 1987 to'1993. Two problems were noted with contacts on an ESW lockout relay failing to operate. The relay was replaced with a new one and the surveillance frequency was increased to quarterly. After seven consecutive tests were performed satisfactorily, the testing frequency was retumed to once per operating cycle.

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Attachment 11 to JPN-95-025 Emergency Service Water System

. SAFETY EVALUATION Page 3 of 5 - -

Extension of this test to 24 months will not adversely affect system performance or

- reliability because: ,

- the relays used by this system have proven to be reliable as documented by numerous tests, and

- all purnps and valves operated by this system are frequently tested with the plant on-line. (Flow rate tests are performed quarterly, pump and MOV operability are checked monthly, instrumentation is checked daily and is calibrated quarterly).

In addition to the surveillance interval extensions for Specifications 4.11.D.1.a and 4.11.D.I.f , Specification 4.11.D.1.e has been administratively rearranged to better clarify the requirements for ESW instrumentation check and instrument channel

- calibration. The "once/3 months" frequency, which appears twice in this specification, has been aligned with the proper (single) surveillance test. No new or different tests or surveillance intervals are proposed by this administrative clarification.

Based on the discussion above, the ESW surveillance tests can be safely extended to accommodate a 24 month operating cycle.

The assumptions in the Fitzpatrick licensing basis are not invalidated by performing the ESW surveillances at the bounding interval limits (30 months) to accommodate the 24 month operating cycle.

IV. EVALUATION OF NO_SIGNIElCANT HAZABDS_ CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed Amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92 since it would not:

1. involve a significant increase in the probability or consequences of an accident previously evaluated.

l The proposed changes increase the interval between ESW system surveillance tests. J These changes are consistent with the guidance provided in Generic Letter 91-04, l These changes do not. involve any physical changes to the plant, nor do they alter the l typical way the ESW system functions. On-line testing will continue to assure -

equipment availability. The type of testing and the corrective actions required if the 1 subject ESW surveillances fail remain the same. As such, the proposed changes create no new impacts on accidents previously evaluated.

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. 1 Attachment 11 to JPN-95-025 Emergency Service Water System  !

SAFETY EVALUATION i Page 4 of 5  !

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes increase the inten/al between ESW system surveillance tests.

These changes are consistent with the guidance provided in Generic Letter E i-04.

The proposed changes do not change the ability of the ESW system to provide heat removal for the ECCS components and other equipment essential to reactor shutdown.

Past equipment performance and on-line testing Indicate the longer test intervals will not degrade ESW equipment. No changes are proposed to the type of testing performed, only to the length of the surveillance interval. The proposed changes do not modify the design or operation of plant equipment, therefore, no new or different failure modes are introduced.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. involve a significant reduction in a margin of safety.

The proposed changes increase the interval between ESW system surveillance tests.

These changes are consistent with the guidance provided in Generic Letter 9104.

The proposed changes do not alter the configuration of the ESW system nor change the manner in which the ESW equipment functions. Past equipment performance and on-line testing indicate the longer test intervals will not degrade ESW equipment.

Operation of the plant remains unchanged by the proposed changes.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

v. IMELEM Et1TAIlotLOE_TH E_EBQP_QSED_GEAtlOf.

Implementation of the proposed changes will not adversely affect the ALARA or Fire Protection Programs at the FitzPatrick plant, nor will the changes affect the environment.

Attachment ll to JPN-95-025 Emergency Service Water System ,

SAFETY EVALUATION Page 5 of 5 VI. . CONCLUSLOR The changes, as proposed, do not constitute an unreviewed safety question as defined in 10 CFR 50.59. That is, they:

1. Will not increase the probability nor the consequences of an accident or malfunction of '

equipment important to safety as previously evaluated in the Safety Analysis Report;

2. will not create'the possibility of an accident or malfunction of a type different from any i previously eva'uated in the Safety Analysis Report;

3. will not reduce the margin of safety as defined in the basis for any technical specification; and

4. Involve no significant hazards consideration, as defined in 10 CFR 50.92. j Vll. BEEEBENCES i

1. Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to I Accommodate 24 Month Fuel Cycle," dated April 2,1991.

2. NYPA Report No. JAF-RPT-SWS-01538, " Service Water System Surveillance Test improvements," dated June,1994.

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ATTACHMENT lli to JPN-95-025 Markup of the current Technical Specification pages Extension of Emergency Service Water System S';rveillance Test intervals in Accommodate 24-MontbSperating CycledJPTS-95-001F)

I New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT 4 Docket No. 50-333 DPR-59

u_ -y JAFNPP -'

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3.11 (cont'd) 4.11 (cont'd) '

D. Emeroency Service Water System . D. Emeroency Service Water System 1 . To ensure adequate equipment and area cooling, both 1. Surveillance of the ESW system shall be p' erformed as ESW systems shall be operable when the requirements of follows:

specification 3.5.A and 3.5.B must be satisfied, except ,

as specified below in specification 3.11.D.2. .

Ram _ Freauency ....-. #

Jo.

.a. Simulated Automatic (Each operating cyWc Actuation Test : ' Once every 24 rnorr&s

b. Flow Rate Test - Each ESW:- Once/3 months

. pump shall deliver at least 1500 gpm to its respective loop. The pump total developed head shall be greater than or equal .-

- to the corresponding point on the pump curve, reduced by a maximum -

of 7%, for the measured flow.

c. Pump Operability- .Once/ month

d. Motor Operated Valves - Once/ month

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, Amendment No. /,1/4, 223 '

240 .

-_.. _ - . _ _ - = _ _ - _ . - _ _ ___-_- --_____x_-_____--_______-__ . _ _ - _ . . . _ _ - . , _ . - - ,.. , . _ _ _ . . _ _ ~

m JAFNPP '

3.11 (cont'd) 4.11 (cont'd)

e. ESW Once/ day g instrumentation- (pnce/3 monthO check

Calibrate tes Once/3 months I

f. Logic System O",Cf ey 24 'Once/each 1 A

Functional Test modih3 < operating cycle

2. From and after the time that one Emergency Service 2. ESW will not be supplied to RBCLC system during Water System is made or found to be inoperable for any testing.

reason continued reactor operation is permissible for a l period not to exceed 7 days, provided thet: EsW ins +rurnen+

the operable Emergency Diesel Generator System is demonstrated to be operable immediately and daily thereafter; and, all Emergency Diesel Generator System emergency loads are verified operable immediately and daily thereafter.

3. If specification 3.11.D.2 cannot be met the reactor shall 3. Not Used l I be placed in the cold condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

I Amendment No.1/I,192 241

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