ML20205R863

Application for Amend to License DPR-54,consisting of Rev 1 to Proposed Amend 172,withdrawing Request to Delete Reactor Bldg Spray Line Requirements & Justifying Removal of DHR Inlet Lines

ML20205R863
Person / Time
Site:	Rancho Seco
Issue date:	11/04/1988
From:	Dewitt R SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20205R867	List: ML20205R863 ML20205R868
References
AGM-NPP-88-583, NUDOCS 8811100153
Download: ML20205R863 (9)

Text

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O esuun SACRAMENTO MUNICIPAL UTIUTY Dl87RK:T O P. O. Bou 15830, Sacramento CA 95852 183o,1916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CAllFORNIA AGM/NPP 88-583 NOV 0 41988 U. S. Nuclear Regulatory Commission A'tn: Document Control Desk i Hi.shington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54  :

PROPOSED AMENDMENT NO. 172. REVISION 1 2

Attention: George Knighton f In accordance with 10 CFR 50.90, the Sacramento Municipal Utility District l

. proposes to amend Operating License DPR-54 for Rancho Seco and therefore l submits Proposed Amendment No. 172 Revision 1.

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i Proposed Amendment No. 172. Revision 1 responds to the NRC's request for j additional information. The District is providing additional information to i justify removal of Decay Heat Removal (DHR) inlet lines and High Pressure Injection (HPI) local leak rate test (LLRT) requirements. The District l withdraws the request to delete Reactor Building spray (RBS) line LLRT '

requirements.

j Attachment I contains the Safety Analysis Report and the No Significant l Hazards Consideration for the changes made by Proposed Amendment No. 172 Revision 1. Attachment !! contains the list of Technical Specification pages affected by Proposed Amendment No. 172 Revision 1 and the proposed t replacement pages, i

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

Since this is a revision to Proposed Amendment No. 172, no additional license j

fees are required. 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 j j amendment is approved prior to December 22.

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, PDb i RANCHO SECO NUCLEAR GENERATING STATION EJ i=44o Twm Cities Road Herald CA 95638 9799;(2o9) 333 2935

i George Knighton AGM/NPP 88-583 Members of your staff with questions requiring additional information or clarification may contact Ms. Ellen Banaghan at (916) 452-3211, extension 4917.

l State of California

! SS County of Sacramento Russell B. DeWitt, being first duly sworn, deposes and says: that he is Acting Assistant General Manager, Nuclear Power Production of Sacramento Municipal Utility District (SMUD), the licensee herein; that he has executed the foregoing 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 execut this document on behalf of said licensee, hay /bI

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Russell B. DeWitt Acting Assistant General Manager Nuclear Power Production Subscribed and affirmed to before me on this Y day of 2d M *M d . 1988.

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- - .I Notary Public Attachments cc w/atch: A. D'Angelo, NRC, Rancho Seco J. B. Martin, NRC, Halnut Creek J. S. McGurk, State of California MIPC (2)

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t ATTACM ENT I Safety Analysis Report and No Significant Hazards Consideration l

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. Safety Analysis Report Log No. 1077. Revision 1 Proposed Amendment No. 172. Revision 1 Pag) I cf 6 ,

4 SAFETY ANALYSIS REPORT  !

1. Dtittiptlon__of Changt; s-Amend Technical Specifications to:

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. (a) Remove Item 10 (Decay Heat Removal inlet lines) and Item 12 (High  !

pressure injection lines) from the required local leak rate tests  ;

(LLRT) (Technical Specification (TS) 4.4.1.2).  !

j (b) Amend Objective of containment integrity Limiting Condition for Operation for consistency with the modes stated in the Applicability i j section. (TS 3.6) i (c) Hodify the test frequency of TS 4.4.1.2.3 to be not greater than 24 j months rather than each refueling interval.  ;

! 2. Reasoftfot Change (a) Local Leak Rate _ Test Changt  !

J i The Decay Heat Removal (DHR) inlet lines and High Pressure Injection i (HPI) lines are being removed from LLRT requirements to provide operational enhancement and reduce radiological exposure. Operation  ;

j will be enhanced by reducing outage time and/or planned outages  :

. required to conduct local tests. Furthermore, equipment availability l

]; will be increased by reduc *ng the total number of tests required for  :

each system. This will be accomplished by removing the penetrations i i noted from LLRT requirements and by ensuring containment integrity by [

j performing existing system integrity tests.  ;

J Radiation exposure will be reduced by not requiring system alignments j and installation of test equipment in radiation areas. Operability ,

1 of the systems can be demonstrated by performing system integrity j tests alone, thus reducing total exposure.

(b) Ob.itc1 Lit..Chanse  !

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i Modification of the Objective is an administrative change for i l consistency between the Objective and the Applicability sectione, f (c) Itit_ErtQutacLChartst i The requirement for the LLRT frequency it being : hanged to provide (

j operational enhancement and reduce radiological exposure. Allowing  ;

performance of tests on a maximum of 24-month intervals prevents i additional tests from being required when more than 18 months has i elapsed between refueling cycles. This will elso reduce plant outage l time by not requiring a plant shutdown if the time between refuelings is extended to between 18 and 24 months. Reducing mid-cycle local l leak rate performances will also reduce radiological exposure.

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Safety Analysis Report Log No. 1077. Revision 1 Proposed Amendment No. 172. Revision 1 Page 2 of 6

3. EYAlMation And Basis For Safety Findines:

j (a) Systems. Subsystems. Components Affected

1) This change modifies the LLRT requirements for the HPI end OHR '

systems. It removes containment penetrations 20, 21, 22, 23 (HPI lines), and 27 and 28 (DHR inlet lines) from those penetrations requiring LLRTs. In addition, the change modifies the -

surveillance period for LLRTs. i l

) The HPI System is Quality Class I (as defined in the USAR,  ;

Appendix 18, page 18-4) and Seismic Category 1 per USAR Section ,

! 6.1.2. As an Emergency Core Cooling System, the HPI is designed t 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  !

i psia) under accident conditions. l i

The OHR System performs the Low Pressure Injection (LPI) function l  !

during post accident conditions. As described in USAR Section ,

6.2, this system is Quality Class 1 and Seismic Category 1 and I has functions during accident conditions stallar to the HPI  !

1 System discussed above.

l The HPI and LPI Systens are redundant loops which have diesel l

generator and battery backed power supplies (see USAR Section .

l 6.2.3).  !

i The HPI and LPI Systems are all closed systems outside of l !

l containment and 11guld-filled systems during post LOCA

conditions. l i

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) 2) This TS change modifies the surveillance period for LLRTs to ,

< conform with requirements cf 10 CFR 50, Appendix J. Paragraph I l III.D.3. The increase in the surveillance interval applies only (

to containment penetrations as listed in TS 4.4.1.2.1.

l (b) Sait.ty_f.unctistLof Affected Systtu l

i HPI and LPI are Safety Features Systems. HPI and LPI provide Reactor '

Coolant System (RCS) inventory and cooling during post LOCA

conditions. ,

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1 The Containment Isolation Systes ensures containment integrity can be .

maintained during post LOCA conditions, i i

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Safety Analysis Report Log No.1077. Revisica 1

-Proposed Amendment No. 172. Revision 1 Page 3 of 6 (c) Efittts on Safety Functions

1) This change does not affect the ability of the Safety Features Systr,ms to perform their design functions. Operability of these systems (including components and flow paths) is required by TS , 3.3 and is survellied per TS Section 4.2. In addition, RCS  ;

pressure boundary leakage is limited by TS 3.1.6.1 and is ,

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I survellied per TS 4.2.3. Thus, the ability of these systems to i perform their intended functions is ensured by existing, unaffected TSs and will not be affected by not requiring LLRTs of l their penetrations. '

l 2) This change does not affect the ability of the Containment l 4

Isolation System to provide containment integrity as designed, t Post LOCA containment integrity will still be maintained as  ;

, described in USAR Section 5.2.4.1. Double barriers will continue ,

! to provide building isolation for low RCS pressure or high i 1 Reactor Building pressure for all other systems. Systems serving i i the function of safety features will remain unisolated as '

1 described in USAR Section 5.2.4.1.

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l 3) Revising the surveillance from up to 18 months to up to 24 months i is in accordance with the surveillance requirements stated in 10  :

CFR 50, Appendix J.Section III.D.3. The penetrations were l designed to ensure operability over a 24-month surveillance  ;

interval per ANSI N271-1976. This change will increase their j j reliability by not placing unnecessary cycles on the components, i j (d) Analysis of Effects ofLSAffty Functions i

l The HPI and LPI Systems are designed to prevent leakage as described in ANSI N271-1976. The injection systems have stop check valves inside containment and a remotely operated valve outside containment. Should a break occur in one of the lines, check valves are provided for imediate automatic isolation and remote manual l

valves for long term isolation.

l The HPI containment penetrations are all fed from a common header

] (cross-tie line not isolated) supplied from both HPI pumps and the Hakeup pump. Therefore, regardless of single active failure, a water seal at greater than 1.10 Pa will still be maintained at these penetrations by the redundant HPI pump.

) Each LPI containment penetration is fed by an LPI pump. There is a I common header that is normally isolated. In the event of LPI pump failure, the cross-tie valve would be opened (see USAR, Table 6.2-5, f Item B.1). Therefore, regardless of single active failure, a water i seal at areater than 1.10 Pa will still be maintained at these

penetratIonsbytheredundantLPIpump.

l q The LPI (Decay Heat System) isolation valves are also tested per l

Specifications 3.1.6.1.f and 4.5.3 for pressure boundary isolation. ,

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I Safety Analysis Report Log No. 1077. Revision 1 Proposed Amendment No. 172. Revision 1 Page 4 Cf 6 j

The outside containment isolation valves are tested periodically in

accordance with TSs. This testing assures capability of the outside t automatic valve to isolate the system for system operation or if required for building isolation. In addition, the requieements for integrated leak rate testing (ILRT) are not being affected by this l change. The ILRT provides additional assurance that containment integrity can be maintained.

Removing the LLRT requirements for HPI and LPI does not degrkde post LOCA containment integrity. The isolation valves affected are open

during long-term post LOCA conditions. Each of these systems i

consists of a closed loop outside of containment that is always

liquid filled. HPI and LPI all take suction from the borated water storage tank (BHST) and discharge into the RCS. During long-tem post LOCA conditions, suction for these systems is transferred to the Reactor Building Sump when the BNST is depleted such that the piping is continuously liquid-filled. Because these systems are 11guld-filled, the possibility does not exist for containment atmosphere to leak outside of the closed systems.

Leakage from the HPI and LP! systems will be in the form of liquid leakage. DHR is survellied for leakage per TS 4.5.3, and HP! 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 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 or.ly leakage that would result is Itquid leakage which has pr etously been analyzed. Thus, removing LLRT requirements from LPI and HPI penetrations would not result in the plant being in an unsafe condition.

(e) SU!rary Proposed Amendment No. 172 amends the Conta..iment Integrity TSs. The change removes LLRT requirements for DHR and HPI, amends the l surveillance period from refueling interval to up to 24 months, and prevides administrative clarification.

The purpose of the change is to provide operational enhancements and reduce personnel exposure by not requiring performance of survetilances between plant refuelings and by removing requirements to test penetrations that do not require LLRTs.

The systems affected are Quality Class 1 - d Seismic Categ0ry 1.

Their safety functions as defined in the b AR 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, Revision 1 Proposed Amendment No. 172. Revision 1 Page 5 Cf 6 This chaage does not present an Unreviewed Safety Question for the following reasons:

• The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the SAR will not be increased becaJse 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 surveillance period.

• The possibility for an accident or malfunction of a different type

' will not be created because the noted systems will be serveilled 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 j specification is not reduced because the system's operation will l not be affected by this change; the penetrations being removed j from testing requirements are not isolated during post LOCA l

conditions and will not result in a degradation of containment i integrity as described in the basis of technical specifications.

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- Safety Analysis Report Log No. 1077. Revision 1

. Proposed Amendment No. 172, Revision 1 Page 6 Cf 6 ,

l NO SIGNIFICANT HAZARDS CONSIDERATION 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 ,

l Analysis the District has concluded that: l p

• A significant increase in the probability or consequences of an [

l accident previously evaluated in the SAR will not be created because  !

ECCS functions will not be affected, and because containment integrity l will be maintained either by water-filled HP! and LPI Systees or by f tested containment isolation valves.

• The proposed amendment will not create the possibility of a new or  :

different kind of accident previously evaluated in the SAR because the (

amendment does not change the o?tration of any systems. In addition, eliminating unnecessary testing reduces equipment operational cycles i and thus improves availability of equipment, resulting in the reduced probability of a new or different type of accident.

• 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 HP! system design) even though LLRT requirements are removed for l and LPI.

Based on the above discussion, the District concludes that the proposed f changes do not constitute any significant hazard to the pblic, and in no l way endanger the public's health and safety. i l

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