ML20098F143

Proposed Changes to Tech Spec 3/4.3.4,deleting Requirement to Cycle Specified Turbine Valves in Modes 2 & 3

ML20098F143
Person / Time
Site:	Catawba
Issue date:	09/26/1984
From:	DUKE POWER CO.
To:
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ML20098F138	List: ML20098F137 ML20098F143
References
NUDOCS 8410020379
Download: ML20098F143 (10)

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Attachment 1 Proposed Amendment to Catawba Unit 1 Technical Specification 3/4.3.4 Concerning Turbine Overspeed Protection

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JUSTIFICATION AND ANALYSIS OF SIGNIFICANT HAZARDS CONSIDERATION This proposed amendment would delete the requirement to cycle the specified turbine valves in Podes 2 and 3. Previous justification was given in Attachment 5 of my oune 5, 1984 letter which transmitted proposed amendments to the Draft Technical Specifications for Catawba Unit 1. Subsequent to that letter a telephone conversation was placed on June 28, 1984 involving Mr.

Giardina of your Staff, Duke Power personnel and employees of General Electric.

During this conversation, the reason for not granting the requested Tech Spec change was discussed. The reason given was that the Catawba Tech Spec was based on the Standard Technical Specification used for General Electric Turbine Generators. It is our opinion, based on the attached July 24, 1984 letter from Mr. J. C. Packard of G. E. to Mr. G. P. Karasiewicz, of my Staff, that the G. E. Standard Tech Spec and the Current Catawba Tech Spec are in error.

10 CFR 50.93 states that a proposed amendment involves no significant hazards consideratic'1s if operation in accordance with the proposed amendment would not:

1) Invol'e a significant increase in the probability or conseqJences of an accident previcusly evaluated; cr

2) Create the possibli M.y of a new of different kind of accident from any accident previously evaluated; or

3) Involve a significant reduction in a margin of safety.

The proposed amendment does not increase the probability or consequences of an accident previously evaluated and'it does not create the possibility of a new or different kind of accident.

The proposed amendment does not involve a significant reduction in a margin of safety. Actually, as discussed in my June 5,1984 letter, testing of the valves during Modes 2 and 3 would involve bypassing the electronic cir-cuits incorporated to protect the turbine from thermal transients and over-speed. Also, testing these valves is not recommended by the manufacturer.

Thus, deleting the requirement to test the turbine valves during Modes 2 and 3 would add to the margin of safety which already exists.

For the reasons described above, it is concluded that the proposed amendment does not involve significant hazards considerations.

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INSTRUMENTATION 3

3/4.3.4 TURBINE OVERSPEED PROTECTION L,IMITING CONDITION FOR OPERATION 1

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3.3.4 At least one Turbine Overspeed Protection System shall be OPERABLE. I APPLICABILITY: MODES 1, 2, and 3.

ACTION:

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a. With one stop valve or one control valve per high prescure turbine steam line inoperable and/or with one intermediate stop valve or one ,

intercept valve per low pressure turbine steam line inoperable, '

restore the inoperable valve (s) to OPERABLE status within 7.! hours, '

or'close at least one valve in the affected steam line(s) or isolate.

the turbine from the steam supply within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. With the above required Turbine Overspeed Protection System otherwise inoperable, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> isolate the turbine from the steam supply.

SURVEILLANCE REOUIREMENTS 4.3.4.1 The provisions of Specification 4.0.4 are not applicable.

4.3.4.2 The above required Turbine Overspeed Protection System shall be demonstrated OPERABLE: 7 '~~ ~ ~

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a. At least once per 7[ days 3by cycling each of the following valves through at least one complete cycle from ,the running position:

1) Four high pressure turbine stop valves,

2) Four high pressure turbine control valves,

3) Six low pressure turbine intermediate stop valves, and

4) Six low pressure turbine-intercept valves.

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b. by direct observation of the movement of At least each position, of the once above valves per 31 days,through one complete cycle from

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At least once per 18 months by performance of a CHANNEL CALIBRATION on the Turbine Overspeed Protection Systems, and

d. At least once per 40 months by disassembling at least one of each of the above valves and performing a visual and surface inspection of valve seats, disks and stems and verifying no unacceptable flaws or corrosion.

t CATAWBA - UNIT 1 3/4 3-91 D

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GENER AL h ELECTRIC ENGINEERING G ENERAL ELECTRIC COMPANY.9801-G SOUTH ERN PINE BOULEVARD. P.O. BOX 240606 SERVICES CHARLOTTE. NORTH CAROLINA 28224, Phone (704) 379-7600 July 24,1984 RECEIVED

SUBJECT:

. CATAWBA #1 AND #2 TURBINES 170X617, X618 m- m PERIODIC OPERATIONAL TEST

SUMMARY

(GEX46527)

"'._.l DUKE FILE CN-200.30 Duke Power Company Nuclear Production Department Post Office Box 33189 Charlotte, NC 28242 AttenLian: Mr. G. P. Karasiewicz Maintenance Engineer Gentlemen :

This will confirm our June 28,1 1984 telephone discussion with you and Messrs.

Lacivita and Carson in Schenectady and NRC personnel .

General Electric turbine valve testing recommendations are based entirely on turbine overspeed protection considerations, and are intended to apply only during periods of turbine operation. GEK 46527, " Periodic Operational Test Summary", summarizes the turbine testing recommer.dations, and the term

" Operational" in the title is intended to refer to turbine operation.

Very truly yours,

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, J. C. Packard

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Service Supervisor Fossil Plant Services ew

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Attachment 2 Proposed Amendment to Catawba Unit 1 Technical Specification 3/4.10.5 Concerning Position Indication System - Shutdown j

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' JUSTIFICATION AND SIGNIFICANT' HAZARDS CONSIDERATION The proposed. amendment would fix an internal conflict currently contained

, in the Catawba Unit 1 Technical Specifications.

~ Specification 3.1.3.3 call: for an operable digital rod position indicator-

while in Modes 3, 4 and 5 with the reactor trip breakers in the closed

. position. Reference is made to Special-Test Exception Specification 3.10.5

which allows ~ suspension' of the requirements of Specification 3.1.3.3 during ,

rod drop time _ measurements.and also during initial calibration of the cPosition Indication System.

The conflict appears when one attempts to verify the operability of an .

inoperable digital rod position indicator. The Action statement for Speci-fication 3.1.3.3 calls for immediately opening the reactor trip breakers upon-discovery offan inoperable indicator (s).. In order to declare an inoperable indicator operable, Surveillance Requirement 4.1.3.3 must be (performed. Specification 4.1.3.3 calls for moving control rods.to verify .

- that the' digital rod position indicator agrees with the demand position ,

indicator within 12 steps. However, . control rods can not be moved with  !

the reactor trip breakers open. Thus.there is no way-to verify the oper-ability of an inoperable position indicator.

In order to resolve this conflict exception must be taken to the applicability of Specification 3.1.3.3 during perfonnance of Surveillance Requirement 4.1.3.3.

10 CFR 50.92 states that a proposed amendment involves no significant hazards.

considerations if operation in accordance-with the: proposed amendment would not:

1) Involve a significar.t increase in the probability.or;

~ ' . consequences of an accident previously evaluated; or

~2 ) ' Create'the possibility of a new or different kind of accident from any accident previously evaluated; or

-3) Involve a significant reduction it a margin of safety.

The procased amendment does not increase the probability or consequences of an accident previously evaluated, it does not create the possibility

, . 'of a new or different kind of accident, and it does not involve a significant

- reduction in a margin of safety. The amendment would allow verifying the L operability of'an inoperable digital rod. position indicator and would remove

anLinternal inconsistency in the Technical Specifications.

[ Thus,-it is concluded that the proposed amendment does not involve signi-s 31 cant hazards considerations.

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SPECIAL TEST EXCEPTIONS 3/4.10.5 POSITION INDICATION SYSTEM - SHUTDOWN

- LIMITING CONDITICN FOR OPERATION 3.10.5 The limitations of Specification 3.1.3.3 may be suspended during the performance of 1.ndividual full-length shutdown and contro1 rod drop time A # ,

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a. Only oriiit'skutdown~or control bankTs withdia~'n~froInihe w fully inserted position at a time, and

b. The rod position indicator is OPERABLE during the withdrawal of the rods.*.

APPLICABILITY:

MODES 3, 4, and 5 during performance of rod drop time measurementg.T ACTION: or Survel//nace Tegu/ wen {. I g/.s.3 --

With the Position Indication System inoperable or witNoie"~thMne b k of rods withdrawn, immediately open the Reactor trip breakers.

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SURVEILLANCE REOUIREMENTS 4.10.5 The above required Position Indication Systems shall be determined to be OPE 2ABLE within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> prior to the start of and at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter during rod drr.p time measurements by verifying the Demand Position l

Indication System and the Digital Rod Position Indichtfon System agree:

l a. Within 12 steps when the rods are stationary, and j b. Within 24 steps during rod motion.

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• This requirement is not a plicable during the 'MtT calibration of N "f'}" V '

Position Indication System provided: (1) K ~ is~ maintained less than v.'

equal to 0.95, and (2)-only one shutdown or*Nntrol rod bank is withdrawn from the fully inserted position at one time.

CATAWBA - UNIT 1 3/4 10-5 l

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Attachment 3 Proposed Amendment to Catawba Unit 1 Technical Specification-Table 3.3-4, Item 8.g Concerning Auxiliary.Feedwater Suction-Pre,sure Switch Trip Setpoints and Allowable

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w JUSTIFICATION AND SIGNIFICANT HAZARDS-CONSIDERATIONS The proposed amendment would change the Allowable Values and Trip Setpoints for the Auxiliary Feedwater Suction Pressure-Low pressure switches. These changes are the result of a recently concluded flood study. The results of-the study concluded in part that the-Auxiliary Feedwater pressure switches needed to,tua relocated. Relocating the pressure switches causes a change in the Trip Setpoints. 'Thus, this amendment request reflects the need to revise those Trip Setpoints and Allowable Value in the-Tachnical Specifications affected by the relocation of the pressure switches.

10 CFR 50.92 states that a proposed amendment involves no significant hazards considerations if operation in accordance with the proposed amendment-would not: ,

1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or

2) Create the possibility of a new or dif ferent kind of accident from any acc122nt previously evaluated; or 30 lavolve c s4.;11ficant reduction in a margin of safety.

The proposed amendment does not increase the probability or consequences of an accident previously evaluated and it does not create the possi-bility'of a new or different kind of accident.

The proposed amendment does not involve a significant reduction in a a margin of. safety in that the proposed changes are values consistent with previcus accident analyses. Thus, it is concluded that the proposed amendment d:es not involve significant hazards con.iderations.

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' TABLE 3.3-4 (Continued) 9 g ENGINEERED SAFETY FEATU."ES ACTUATION SYSTEN INSTRUNENTATION TRIP SETPOINTS c

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TOTAL ERR 0d j g FUNCTIONAL UNIT ALLOWANCE (TA) Z (S) TRIP SETPOINT ALLOWA6LE VALUE l Q g 8. Auxiliary Feedwater (Continued) -

! c. Steam Generator Water 15 12.18 i 1. 5 > 17% of span > 10.25% of Level - Low-Low

Trom 0% to ipan from 0% to .

1 30% RTP 30% RTP increasing .

! . increasing linearly to .

linearly to > 53.2% of span .

! > 54.9% of from 30% to 100%

j ipan from 30% RTP i to 100% RTP y d. Safety Injection See Item 1. above for all Safety Injection Setpoints'and Allowable Values.

f e. Loss-of-Offsite Power N.A. N.A.

N.A. 1 3500 V > 3200 V j f. Trip of All Nain Feedwater l Pumps N.A. N.A. N.A. N.A. N.A.

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g. Aux!!iary Feedwater Suction 3 Pressure-Low l 1) 1 CAPS 5220, 5221, 5222 N.A. H.A. N.A. 1 10.5 psig

1 9.5 psig

2) 1 CAPS 5230, 5231, 5232 N.A.

,m s N.A. N.A. >fte + psig 14&.psig

9. Containment Sump Recirculation v

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! a. Automatic Actuation Logic H.A. N.A. N.A. N.A. N.A. '

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and Actuation Relays

) b. Refueling Water Storage N.A. N.A. N.A.

! Tank Level-Low 1 177.15 inches 1 162.4 inches Coincident With Safety

} , Injection See Item 1. above for all Safety Injection Setpointf. and Allowable Values.

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