ML20154J552

Application for Amend to License DPR-54,consisting of Proposed Amend 172,changing Local Leak Rate Test Requirements for Containment Penetrations.Fee Paid

ML20154J552
Person / Time
Site:	Rancho Seco
Issue date:	09/19/1988
From:	Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Knighton G NRC, NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20154J554	List: ML20154J552 ML20154J561
References
AGM-NPP-88-509, NUDOCS 8809230063
Download: ML20154J552 (10)

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$suun SACRAMENTO MUNICIPAL UTILITY DISTRICT O P. O. Box 1583o. Sacramento CA 95852 183o,(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART Or CALIFORNIA AGH/NPP 88-509 SEP 101988 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Hashington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 PROPOSED AMENDNENT NO. 172 Attention: George Knighton In accordance with 10 CFR 50.90, the Sacramento Municipal Utility District I proposes to amend Operating License DPR-54 for Rancho Seco and therefore submits Proposed Amendment No. 172.  ;

Proposed Amendment No. 172 changes local leak rate test (LLRT) requirements for containment penetrations. The change removes from LLRT requirements those penetrations that are normally liquid-filled during post LOCA conditions and changes the surveillance period for the remaining LLRTs.

Attachment I contains the Safety Analysis Report and the No Significant Hazards Consideration for the changes made by Proposed Amendment No. 172.

Attachment II contains the list of Technical Specification pages affected by Proposed Amendment No. 172 and the proposed replacement pages.

Pursuant to 10 CFR 50.91(b)(1), the Radiological Health Branch of the California State Department of Health Services has been informed of Proposed Amendment No. 172 by mailed copy of this submittal.

Enclosed is a check in the amount of $150.00 as required by 10 CFR 170.21, l "Schedule of Fees." Expeditious review of this proposed amendment is requested as a plant shutdown will be required prior to December 22, 1988, to satisfy existing Technical Specifications. This shutdown will not be required if this amendment is approved prior to December 22. '

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$ 9Ho8 RANCHO SECO NUCLEAR GENERATING STATION O 1444o Twin Cities Road, Herald, CA 95638 9799:12o9) 333 2935

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$EP 191988 George Knighton AGM/NPP 88-509 I

Hembers of your staff with questions requiring additional information or clarification may contact Ms. Ellen Banaghan at (916) 452-3211, extension 4917.

State of California SS County of Sacramento Dan R. Keuter, being first duly sworn, deposes and says: that he is Assistant

General Manager, Nuclear Power Production of Sacramento Municipal Utility District (SMUD), the licensee herein; that he has executed the foregoing i document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute this document on behalf of said licensee. ,

Dan R. Keuter Assistant General Manager t Nuclear Power Production Subscribed and affirmed to before me on this N ay of Lb It o , 1988.

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"ES6TCTOM I

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y/" ' M' ESTHER H. HME3 Esther H."Hughes "

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. ,2 +7a normeuc wowa (

hg. gew,aao cuedy Notary Public F' 'j v,c:<m Srm *od' R Q" 6 M. e Attachments t cc w/atch: A. D'Angelo, NRC, Rancho Seco ,

i J. B. Hartin, NRC, Halnut Creek '

! MIPC (2)

I INPO J. S. McGurk, State of California '

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SEP 19 1%8 George Knighton AGM/NPP 88-509 bc:

w/atch w/o atch X General Manager MS 41

_X_ Chief Executive Officer, Nuclear MS 209 X AGM, Plant Support Services MS 259 AGH, Technical Services MS 206

• X AGH, Nuclear Power Production MS 254

_X_ ___

Director, Nuclear Quality MS 271 Hanager, Nuclear Training MS 296 3 _X_ Manager, Licensing MS 298 X Hanager, Nuclear Engineering MS 208-6 Hanager, Cost Control Services MS 208-10

_X_ Public Information MS 204 Hanager, Maintenance MS 254 Plant Support Eng. Manager MS 208-5

_X_ ___

Hanager, Operations MS 255

___ Hanager, Envir. Hon. & Emer. Prep. MS 292A Manager, Rad. Protection MS 244 l Hanager, Nuclear Chemistry MS 250

_X_ ___

Manager, Plant Performance MS 258 i i Manager, Safety & Risk Hgmt. MS 40 i ___

MSRC Secretary (R. Colombo) MS 256 4 ___ Surveillance Coordinator MS 278

_X_ ___ IIRG HS 298

_X_ NAC (4) HS 204

X T. Baxter i ___ ___ F. Burke (B&W)

___ D. Seavers (ANI)

___ LER Files MS 298 X ___ Licensing Correspondence Tracking MS 286

_X ___

PRC Secretary (R. Colombo) MS 256 a X RIC Files 98.402 MS 224

___ Special Report Files MS 286  :

___ Tech. Spec./PA Files MS 298 i X ___ NOV/N00 Files MS 286 Licensing Verification MS 286 X ___ Elizabeth Gebur MS 298 X_ ___ Jerry Delezenski HS 298  !

X ___ BHOG T.S. Committee (8)

_X ___

Project Mgr., Procedure Development MS 213 '

X Projects / Procedures Operations Supt. MS 251 X- Plant Support Group Supervisor MS 208-5 I

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ATTACHHENT I Safety Analysis Report and No Significant Hazards Consideration I

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l Safety Analysis Report Log No. 1077 -

Proposed Amendment No. 172 Page 1 of 6 SAFETY ANALYSIS REPORT

1. Description of Channe*

Amend Technical Specifications to: -

(a) Remove Item 10 (Decay Heat Removal Inlet Lines), Item 11 (Reactor l Building spray inlet lines), and Item 12 (High pressure injection  !

lines) from the required local leak rate tests (LLRT) [ Technical i Specification (TS) 4.4.1.2). l (b) Amend Objective of containment integrity Limiting Condition for Operation for consistency with the modes stated in the Applicability  !

section. (TS 3.6) l (c) Modify the test frequency of TS 4.4.1.2.3 to be not greater than 24 l months rather than each refueling interval. l f

2. Reason for Change:

(a) Local Leak Rate Test Chance j The Decay Heat Removal (DHR) inlet lines, Reactor Building Spray I (RBS) inlet lines and High Pressure Injection (HPI) lines are being l removed from LLRT requirements to provide operational enhancement and l reduce radiological exposure. Operation will be enhanced by reducing  :

outage time and/or planned outages required to conduct local tests. l Furthermore, equipment availability will be increased by reducing the i total number of tests required for each system. This will be accomplished by removing the penetrations noted from LLRT requirements and by ensuring containment integrity by performing l existing system integrity tests.  ;

t Radiation exposure will be reduced by not requiring system alignments  !

and installation of test equipment in radiation areas. Operability  ;

of the systems can be demonstrated by performing system integrity  ;

tests alone, thus reducing total exposure. l l

(b) Obiettive Chanae  !

I Modification of the Objective is an administrative change for i consistency between the Objective and the Applicability sections, j (c) Test Freauency Chanae i The requirement for the LLRT frequency is bein changed to provide operational enhancement and reduce radiologica exposure. Allowing 1 performance of tests on a maximum of 24-month intervals prevents I additional tests from being required when more than 18 months has j elapsed between refueling cy:les. This will also reduce plant outage  !

time by not requiring a plant shutdown if the time between refuelings I is extended to between 18 and 24 months. Reducing mid-cycle local  !

leak rate performances will also reduce radiological exposure.  ;

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Safety Analysis Report Log No. 1077 Proposed Amendment No. 172 Page 2 of 6

3. Evaluation And Basis For Safety Findinas:

(a) Systems. Subsystems. Comennants Affected

1) This change modifies the LLRT requirements for the HPI, RBS and ,

DHR systems. It removes containment penetrations 20, 21, 22, 23 (HPI lines); 25 and 26 (RBS inlet lines); and 27 and 28 (DHR inlet lines) from those penetrations requiring LLRTs. In addition, the change modifies the surveillance period for LLRTs.

The HPI System is Quality Class I and Seismic Category 1 per USAR Section 6.1.2. As an Emergency Core Cooling System, the HPI is designed to operate under accident conditions: the isolation valves are open and the system remains water-filled and pressurized to greater than the maximum containment atmospheric pressure (52 psia) under accident conditions.

The DHR System performs the LPI function during post accident conditions. As described in USAR Section 6.2, this system is Quality Class 1 and Seismic Category 1 and has functions during accident conditions similar to the HPI System discussed above. ,

The RBS System is a Safety Feature System and is designated Quality Class 1 and Seismic Category 1 (USAR Section 6.1.1). The system is designed to operate under post-accident conditions and ,

remains water-filled and pressurized to greater than 52 psia long l term.

The HPI, LPI, and RBS systems are all closed systems outside of containment and liquid-filled systems during post LOCA conditions.

2) This TS change modifies the surycillance period for LLRTs to conform with requirements of 10 CFR 50 Appendix J. Paragraph III.D 3. The increase in the surveillance interval applies only  ;

to containment penetrations as Itsted in TS 4.4.1.2.1. 1 (b) Safety Functions of Affected Systems HPI, LPI, and RBS are Safety Features Systems. HPI and LP7 provide Reactor Coolant System (RCS) inventory and cooling during post LOCA I conditions, and RBS functions to reduce Reactor Building atmosphere pressure and to remove iodine from the atmosphere.

The Containment Isolation System ensures containment integrity can be maintained during post LOCA conditions.

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Log No. 1077 '

Safety Analysis Report l

Proposed Amendment No. 172 Page 3 of 6 l (c) Effects on Safety Functions

1) This change does not affect the ability of the Safety Features Systems to perform their design functions. Operability of these i

! systems (including components and flow paths) is required by TS

3.3 and is survet led per TS Section 4.2. In addition RCS l pressure boundary leakage is limited by TS 3.1.6.1 and is surveilled per TS 4.2.3. Thus, the ability of these systems to j perform their intended functions is ensured by existing, unaffected TSs and will not be affected by nct requiring LLRTs of  :

their penetrations. i l

! 2) This change does not affect the ability of the Containment d Isolation System to provide containacnt integrity as designed, i Post LOCA containment integrity will still be maintained as  :

! described in USAR Section 5.2.4.1. Double barriers will continue l

! to provide building isolation for low RCS pressure or high  !

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Reactor Building pressure for all other systems. Systems serving i 1

the function of safety features will remain unisolated as ,

j described in USAR Section 5.2.4.1.

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3) Revising the surveillance from up to 18 months to up to 24 months  !

l 1s in accordance with the surveillance requirements stated in 10  !

j CFR 50, Appendix J.Section III.D.3. The penetrations were f designed to ensure operability over a 24-month surveillance i' j interval per ANSI N271-1976. This change will increase their

! reliablitty by not placing unnecessary cycles on the components.

, i l (d) &Dalysis of Effects on Safety Functions {

1 i The HPI, LPI and RSS systems are designed to prevent leakage as  !

described in ANSI N271-1976. The injection systems and spray systems  ;

l each have stop check valves inside containment and a remotely  :

operated valve outside containment. Should a break occur in one of

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J j the lines, check valves are provided for immediate automatic i isolation and remote manual valves for long term isolation.

l The outside containment isolation valves are tested periodically in j accordance with TSs. This testing assures capability of the outside automatic valve to isolate the system for system operation or if required for building isolation. In addition, the requirements for

! integrated leak rate testing (ILRT) are not being affected by this change. The ILRT provides additional assurance that containment

,t integrity car be maintained.

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t Safety Analysis Report Log No. 1077 Proposed Amendment No. 172 Page 4 of 6 Removing the LLRT requirements for RBS, HPI and LPI does not degrade post LOCA containment integrity. The isolation valves affected are open during long-term post LOCA conditions. Each of these systems consists of a closed loop outside of containment that is always liquid filled. RSS. HPI and LPI all take suction from the borated water storage tank (BNST) and discharge into the RCS. During long-term post LOCA conditions, suction for these systems is transferred to the koactor Butiding Sump when the BNST is depleted such that the piping is continuously liquid-filled. Because these systems are liquid-filled, the' possibility does not exist for containment atmosphere to leak outside of the closed systems.

Leakage from the RSS, HPI and LPI systems will be in the form of licuid leakage. R85 and DHR are surveilled for leakage per TS 4.5.3, anc HPI is monitored for leakage daily while in service. The leakage is analyzed in USAR Section 6.5. This leakage is less than an amount which would result in radiation exposure in excess of 10 CFR 100 limits.

In the event the R85, HPI or LPI line breaks inside the building concurrent with containment building post LOCA conditions, the containment atmosphere does not have the possibility of escaping to an open system even if the containment isolation valves leak.

Because these systems are liquid-filled, the only leakage that would result is liquid leakage which has previously been analyzed. Thus, removing LLRT requirements from RBS, LPI and HPI injection penetrations would not result in the plant being in an unsafe condition.

(e) Summary Proposed Amendment No. 172 amends the Containment Integrity TSs. The change removes LLRT requirements for RBS, DHR and HPI, amends the surveillance period from refueling interval to up to 24 months, and i provides administrative clarification. i The purpose of the change is to provide operational enhancements and  :

reduce personnel exposure by not requiring performance of j surveillances between plant refuelings and by removing requirements  !

to test penetrations that do not require LLRTs. l l

The systems affected are Quality Class 1 and Seismic Category 1.

Their safety functions as defined in the USAR would not be affected by this amendment. Additionally, this change does not affect accident analysis as described in Chapter 14 of the USAR.

' Safety Analysis Report Log No. 1077 Proposed Amendment No. 172 Page 5 of 6 i

This change does not present an Unreviewed Safety Question for the l following reasons:

• The probability of occurrence or the consequences of an accident L or malfunction of equipment important to safety previously ,

evaluated in the SAR will not be increased because the safety functions of the equipment affected will be maintained, containment isolation will not be degraded by removal of LLRT requirements for the noted systems, and the containment isolation has been designed for (in accordance with 10 CFR 50, Appendix J) a 24-month survelliance period. ,

• The possibility for an accident or malfunction of a different type will not be created because the noted systems will be surveilled  :'

to ensure their operability. Reduction in unnecessary equipment operation for testing will reduce system degradation.

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• The margin of safety as defined in the basis for any technical i specification is not reduced because the system's operation will not be affected by this change; the penetrations being removed from testing requirements are not isolated during post LOCA conditions and will not result in a degradation of containment integrity as described in the basis of technical specifications. ,

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e Safety Analysis Report Log No. 1077 Proposed Amendment No. 172 Page 6 of 6 NO SIGNIFICANT HAZARDS CONSIDERATION I

The District has reviewed the proposed change against each of the criterion of 10 CFR 50.92, and based on the discussion in the above Safety '

Analysis the District has concluded that:

s A significant increase in the probability or consequences of an accident previously evaluated in the SAR will not be created because

< ECCS functions will not be affected, and because containment integrity will be maintained either by water-filled RBS, HPI and LPI systems or by tested containment isolation valves.

J e The proposed amendment will not create the possibility of a new or different kind of accident previously evaluat d in the SAR because the amendment does not change the operation of any systems. In addition, eliminating mnecessary testing reduces equipment operational cycles and thus tr<; roves availability of equipment, resulting in the reduced 4 probability of a new or different type of accident.

1 e The proposed amendment will not involve a significant reduction in the margin of safety because system operation is not affected by this  !

amendment, and because containment integrity will still be ensured (due to liquid system design) even though LLRT requirements are removed for RBS, HPI and LPI, l Based on the above discussion, the District concludes that the proposed j

+ changes do not constitute any significant hazard to the pubite, and in no >

I way endanger the public's health and safety,  ;

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