ML20215L835
| ML20215L835 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 05/04/1987 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | |
| Shared Package | |
| ML20215L818 | List: |
| References | |
| 1377, TAC-66415, NUDOCS 8705120392 | |
| Download: ML20215L835 (14) | |
Text
7 APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. l' Enclosed is a requested change to the Davis-Besse Nuclear Power Station,-
Unit No. I Facility Operating License No. NPF-3. Also included are the Safety Evaluation and Significant Hazards Consideration.
The proposed change (submitted under cover letter Serial No. 1377) concern:
Section 3/4.7, Plant Systems, Specification 4.7.1.2d, Auxiliary Feedwater System.
By D. C. Shelton, Vice President, Nuclear Sworn to and subscribed before me this 4th day of May, 1987.
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Rotarp Public, State of Ohio My commission expires t C3~, ,/, f,/
8705120392 870504 PDR ADOCK 05000346 P PDR
p Docket-No. 50-346 License No. NPF-3 Serial No. 1377 Attachment The following information is-provided to support issuance of the requested' change to-the Davis-Besse Nuclear Power Station, Unit-No. 1 Operating License No..NPF-3, Appendix A, Technical Specification 4.7.1.2d.
_A. Time required to implement: This change is to be effective 30 days after issuance of the License Amendment.
B. Reason for Change (Facility Change Request Fo. 87-0056): Revise Technical Specifications to delete a portion of the Surveillance Requirement (4.7.1.2d) which requires that the AFPT inlet steam pressure interlocks shall be demonstrated operable. This deletion is as a result of the main steam line piping to the AFPTs being modified following the June 9, 1985 loss of feedwater event.
C. ~ Safety Evaluation: See attached Safety Evaluation (Attachment 1).
D.- Significant Hazards Consideration: See attached Significant Hazards Consideration (Attachment 2).
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" ~ - Dockst Ns. 50-346 License No. NPF-3 Serial No. 1377
-Attachment 1 Page 1-SAFETY EVALUATION INTRODUCTION The purpose of this License Amendment is'to' revise the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specification Section 3/4.7.1.2. Specifically, this request proposes to delete a portion of the Surveillance Requirement in Speci-fication 4.7.1.2d, which requires that the Auxiliary Feed Pump Turbine
-(AFPT) inlet steam l pressure interlocks shall be demonstrated operable by performance of channel functional test at least once per 31 days'and a channel calibration at least once per 18 months.
SYSTEMS AFFECTED Auxiliary Feedwater System DOCUMENTS AFFECTED Technical Specification 4.7.1.2d REFERENCES
- 1. - Response to NRC Question No. 13 in the Davis-Beste Course of Action Document, Serial No. 1208, dated November 16, 1985 2.- ~Impell Report No. 02-1040-1334, Revision 0, November, 1985, Evaluation of Environmental Conditions from Auxiliary Feedwater Pump Turbine Steam Supply Line Ruptures.
- 3. The NRC Safety Evaluation Report Related to the Restart of Davis-Besse Nuclear Power Station, NUREG-1177, Log No. 1997, dated June 10, 1986
- 4. USAR Section 3.6.2.7.1.4, Main Steam to the Auxiliary Feed Pump Turbines SAFETY FUNCTIONS OF SYSTEMS AFFECTED The safety function of the Auxiliary Feedwater (AFW) System is to provide emergency cooling water to the Steam Generators in case main feedwater is lost due to anticipated transients or postulated accidents. The AFW system is also used to establish natural circulation in the Reactor Coolant System (RCS) following loss of four Reactor Coolant Pumps. The AFW system is capable of cooling down the RCS to the point where the Decay Heat System can be placed into service.
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[ / ' Docket'No.-50-346' jg .Licen'se'No. NPF-3' Seriel No. 1377 LAttac}ysent 1 iPage L 1
-:The safetyifunction of the 'AFPT inlet steam pressure . interlock is to ;
Jdetectfa high energy:line break'in portions of the AFPT main steam piping-
'and alertit he operator to terminate the steam' blowdown to-the Auxiliary 1Euilding. This-interlock also initiates automatic closure oflthe
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applicable'6" steam isolation. valves (MS106 and MS106A or MS107 and
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MS107A)-to-isolate the break.'
AMENIMENT REQUEST-DISCUSSION l Technical Specification 4'.7.1.2d requires that the Auxiliary Feed Pump- '
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.(AFP): turbine inlet steam pressure interlocks shall be demonstrated-operable'by performance of a channel functional test at least once per 31 days and a channe1' calibration at.least once per.18 months. As inferred
.from this Technical Specification, operability of this pressure interlock is_ required to demonstrate operability of the AFW System.
-Pr'essureiswitches PSL-106A thru D and PSL-107A thru D are covered by;this 1 Technical, Specification. . These pressure switches are located.on the-AFPT
. steam inlet piping-just upstream of the steam admission valve MS5889A and MS5889B (see-Figure attached).. . These switches detect breaks in the.
portion af pressurized 6"sAFPT main 1 steam piping in the-Auxiliary Building, that is ~ downstream of the check valves MS734 and MS735 'in the crossover-piping andl check valves MS726 and.MS727 in the AFPT Main Steam piping. A
- double-ended ruptureuin this portion of the 6" main steam piping.would
'depressurize.the piping up to the AFPT-steam admission valves. Upon
. detection.of.a low pressure condition the pressure switch interlock will:
activate an. alarm in the control room and isolate the appropriate steam line valves MS106 and MS106A or MS107 and MS107A. The pressure switch interlock.is designed such that two parallel trip schemes exist for each 1AFW train .Each scheme consists of two pressure switches in series (e.g.
-PS-107A and PSL-107C). Tripping of both switches in series is required-
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Lto trip the scheme. However, only one scheme-needs to trip to close the.
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appropriate steam isolation valves for each train'and to actuate an alarm
- inithe control. room. . Consequently, a low pressure signal from one channel of PSL-106 (PSL-107) would close MS-106 (MS-107) and MS-106A
'(MS-107A). During normal; operation only MS-106A and MS-107A are.open.
i The' closure of the isolation valves via this pressure-switch interlock
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terminates the steam blowdown in the Auxiliary Building and mitigates-the
, consequences of the-high energy line break (HELB).
Prior to June 9, 1985, the main steam piping to the AFPT was normally at Latmospheric-pressure when the plant was operating. This resulted in the
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[1.' pressure switches being in their tripped state. Following a Steam and
' Feedwater Rupture Control System (SFRCS) actuation signal, the steam ll .
i; ' isolation valves associated with the AFPTs (MS106 and MS107) opened
- thereby pressurizing the steam lines. Pressurizing the steam lines above the pressure' switch trip setpoint caused the pressure switches to change-state 1 thereby' preventing'the pressure switches from both alarming in the E
control room and sending a signal to close the valves after they opened.
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- Dock;t N . 50-346 License No. NPF-3 Serial No. 1377
' Attachment 1 Page 3 Under these conditions, the pressure switches must change state following AFW actuation to ensure availability of the AFW system. Failure of the pressure switches to change state when the 6" main steam line pressurized would have caused the 6" main steam isolation valves to close thereby preventing operation of the associated AFW pump. Since the failure of these switches in their tripped state would render the AFW system inoperable, it was necessary to periodically verify operability of the pressure switches. Thus, this mode of operation required the inclusion of the pressure interlocks in the Technical Specification to demonstrate operability of the AFW system.
Following the June 9, 1985 loss of feedwater event the design of the 6" main steam line piping to the AFPTs was revised. With the revised system configuration the steam lines are always maintained in a pressurized hot condition. In this configuration the AFPT steam inlet pressure switches will be in the normal state (high pressure) unless the steam line pressure at the pressure switches drops below the setpoint. In addition to isolating the steam lines, a low pressure condition at the pressure switches will also actuate an alarm in the control room to alert the operator of this condition. Thus, during power operation the operator will become aware of any failures of this interlock that render the AFW system inoperable by closing the steam isolation valves (MS106A or MS107A) due to the interlocks alarming in the control room. Thus, periodic verification of operability of this interlock is no longer required to demonstrate operability of the AFW System.
A failure of these switches in the normal state (high pressure) will affect the environmental qualification of equipment in the Auxiliary Building in the event of a HELB in the 6" AFPT steam line. The analyses submitted to the NRC in the Davis-Besse Course of Action document (Reference 1) evaluated the environmental conditions resulting from the postulated ruptures in this steam piping. These analyses (Reference 2) assumed that the pressure switches will detect the breaks and actuate an alarm in the control room to alert the operator. These analyses assumed a limiting single failure of the open main steam isolation valve (MS106A or MS107A) to close. The Auxiliary Building environmental conditions were determined using the assumption that within ten minutes of detection of the break the control room operator takes necessary manual actions to terminate the steam blowdown to the Auxiliary Building. Without the actuation of low pressure alarms in the control room to alert the operator, the steam blowdown to the Auxiliary Building will not be terminated as quickly. Extended steam blowdown could cause equipment failures due to the generation of more severe temperature environment in the Auxiliary Building than was assumed as part of the Environmental Qualification (EQ) Program. For the above reasons, the pressure switches and the alarm functions will be retained in the plant configuration.
However, as stated in the preceding paragraph, operability of this interlock is not required to demonstrate operability of the AFW system.
- Dock;t Ns. 50-346 License No. NPF-3 Serial No. 1377 Attachment 1 Page 4 Based on the above it is concluded that the Surveillance Requirement in the Technical Specification to demonstrate AFPT steam inlet pressure interlock operability is not applicable to AFW System operability verification and it can be deleted from the Technical Specifications.
Since the Davis-Besse EQ Program takes credit for these pressure switches to alarm in the control room, administrative controls will be established to require that operability of the pressure switches be verified at least once per 31 days. These administrative controls will also require that channel calibration be performed at least once per 18 months. This will assure that the environmental conditions assumed in the EQ Program will not be exceeded due to postulated piping failures in the AFPT steam inlet lines.
The Bases to Technical Specification 3/4.7.1.2 are not affected by this proposed change.
UNREVIEWED SAFETY QUESTION EVALUATION j The proposed action would not increase the probability of occurrence of an. accident previously evaluated in the Updated Safety Analysis Report (USAR) because this change does not involve a modification to a system or a component in the plant (10CFR50.59 (a) (2) (i)) .
The proposed action would not increase the consequences of an accident previously evaluated in the USAR. It is demonstrated above that with the present configuration of the 6" main steam lines to the AFPT the periodic verification of operability of this low pressure interlock is not required to assure operability of the AFW system. Although this action deletes the Surveillance Requirement from the Technical Specification, administrative controls will be established to require that operability of the pressure switches be verified at least once per 31 days and channel calibration be performed at least once per 18 months. This will assure that the environmental conditions assumed in the qualification of electrical equipment are not exceeded during postulated accident conditions. The NRC has reviewed the new HELB analyses which did not take credit for the automatic isolation of AFPT steam line and concluded that the results are acceptable (10CFR50.59(a)(2)(1)).
The proposed action would not increase the probability of a malfunction of equipment important to safety previously evaluated in the USAR. The proposed change does not involve a modification to a system or a component in the plant. It is demonstrated above that the periodic verification of operability of this low pressure interlock is not required to assure oper-ability of the AFW system. Although this action deletes the surveillance requirement from the Technical Specification, administrative controls will be established to require that operability of the pressure switches be verified at least once per 31 days and channel calibration be performed at least once per 18 months. This will assure proper operation of the pressure switches (10CFR50.59(a)(2)(1)) .
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, a J ' Docket No. 50-346 License No. NPF-3 i Serial No. 1377 - -
Attachment 1-Page 5' The proposed action.would not increase the consequences of a malfunction of equipment important to safety previously evaluated;in the USAR. It is demonstrated above1that-the periodic verification'of operability of this-low pressure interlock is not required,to assure operability'of the AFW' isystem. Although this action deletes the surveillance requirement from
- the' Technical Specification, administrative controls will be established to require that operability of the pressure switches be verified'at least once per 31 days and channel calibration be performed at least once per 18 months. This williassure that the environmental. conditions assumed in the' qualification of electrical equipment are not exceeded during postulated accident conditions (10CFR50.59(a)(2)(1)) . -
The proposed action would not create a possibility for an accident of a different type.than any previously evaluated in the USAR. The proposed
' action does not involve modification to any plant system or equipment and
'does'not alter the performance of actual testing in the plant for any equipment (10CFR50.59 (a) (2) (ii) ) .
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The proposed action would not create a malfunction of a different type than any previously evaluated in the USAR. The proposed action does not involve modification to any plant system or equipment and does not alter the performance of actual testing in the plant for any equipment
-(10CFR50.59 (a) (2) (11)) .
The proposed action would not reduce the margin of safety as defined in the bases for.this Technical. Specification because-it is demonstrated above that the AFW system operability is not affected by this change
- (10CFR50.59 (a) (2) (iii)) .
CONCLUSION Pursuant to.above'it is concluded that the proposed action does not involve an unreviewed safety question.
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7 Dock:t N2. 50-346 License No. NPF-3 Serial No. 1377 Attachment 2 Page 1 SIGNIFICANT HAZARDS CONSIDERATION INTRODUCTION The purpose of this License Amendment is to revise the Davis-Besse Nuclear Power Station Unit No. 1 Operating License, Appendix A.
Technical Specification Section 3/4.7.1.2. Specifically, this request proposes to delete a portion of the Surveillance Requirement in Speci-fication 4.7.1.2d, which requires that the Auxiliary Feed Pump Turbine (AFPT) inlet steam pressure interlocks shall be demonstrated operable by performance of channel functional test at least once per 31 days and a channel calibration at least once per 18 months.
SYSTEMS AFFECTED Auxiliary Feedwater System DOCUMENTS AFFECTED Technical Specification 4.7.1.2d REFERENCES
- 1. Response to NRC Question No. 13 in the Davis-Besse Course of Action Document, Serial No. 1208, dated November 16, 1985
- 2. Impell Report No. 02-1040-1334, Revision 0, November, 1985 Evaluation of Environmental Conditions from Auxiliary Feedwater Pump Turbine Steam Supply Line Ruptures.
- 3. The NRC Safety Evaluation Report Related to the Restart of Davis-Besse Nuclear Power Station, NUREG-1177, Log No. 1997, dated June 10, 1986
- 4. USAR Section 3.6.2.7.1.4, Main Steam to the Auxiliary Feed Pump Turbines SAFETY FUNCTIONS OF SYSTEMS AFFECTED The safety function of the Auxiliary Feedwater (AFW) System is to provide emergency cooling water to the Steam Generators in case main feedwater is lost due to anticipated transients or postulated accidents. The AFW system is also used to establish natural circulation in the Reactor Coolant System (RCS) following loss of four Reactor Coolant Pumps. The AFW system is capable of cooling down the RCS to the point where the Decay Heat System can be placed into service.
Dock:t NJ. 50-346 License No. NPF-3 Serial No. 1377
. Attachment 2 Page 2 The safety function of the AFPT inlet steam pressure interlock is to detect a high energy line break in portions of the AFPT main steam piping ard alert the operator to terminate the steam blowdown to the Auxiliary Railding. This interlock also initiates automatic closure of the applicable 6" steam isolation valves (MS106 and MS106A or MS107 and MS107A) to isolate the break.
AMENDMENT REQUEST DISCUSSION Technical Specification 4.7.1.2d requires that the Auxiliary Feed Pump (AFP) turbine inlet steam pressure interlocks shall be demonstrated operable by performance of a channel functional test at least once per 31 days and a channel calibration at least once per 18 months. As inferred from this Technieni Specification, operability of this pressure interlock is required to demonstrate operability of the AFW System.
Pressure switches PSL-106A thru D and PSL-107A thru D are covered by this Technical Specification. These pressura switches are located on the AFPT steam inlet piping just upstream of the steam admission valve MS5889A and MS5889B (see Figure attached). These switches detect breaks in the portion of pressurized 6" AFPT main steam piping in the Auxiliary Building that is downstream of the check valves MS734 and MS735 in the crossover piping and check valves MS726 and MS727 in the AFPT Main Steam piping. A double-ended rupture in this portion of the 6" main steam piping would depressurize the piping up to the AFPT steam admission valves. Upon detection of a low pressure condition the pressure switch interlock will activate an alarm in the control room and isolate the appropriate steam line valves MS106 and MS106A or MS107 and MS107A. The pressure switch interlock is designed such that two parallel trip schemes exist for each AFW train. Each scheme consists of two pressure switches in series (e.g.
PS-107A and PSL-107C). Tripping of both switches in series is required to trip the scheme. However, only one scheme needs to trip to close the appropriate steam isolation valves for each train and to actuate an alarm in the control room. Consequently, a low pressure signal from one channel of PSL-106 (PSL-107) would close MS-106 (MS-107) and MS-106A (MS-107A). During normal operation only MS-106A and MS-107A are open.
The closure of the isolation valves via this pressure switch interlock terminates the steam blowdown in the Auxiliary Building and mitigates the consequences of the high energy line break (HELB).
Prior to June 9, 1985 the main steam piping to the AFPT was normally at stmospheric pressure when the plant was operating. This resulted in the pressure switches being in their tripped state. Following a Steam and Feedwater Rupture Control System (SFRCS) actuation signal, the steam isolation valves associated with the AFPTs (MS106 and MS107) opened thereby pressurizing the steam lines. Pressurizing the steam lines above the pressure switch trip setpoint caused the pressure switches to change state, thereby preventing the pressure switches from both alarming in the control room and sending a signal to close the valves after they opened.
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- Docket No. 50-346 License No. NPF-3 Serial No. 1377 Attachment 2 Page 3 Under these conditions, the pressure switches must change state following AFW actuation to ensure availability of the AFW system. Failure of the pressure switches to change state when the 6" main steam line pressurized would have caused the 6" main steam isolation valves to close thereby preventing operation of the associated AFW pump. Since the failure of these switches in their tripped state would render the AFW system inoperable, it was necessary to periodically verify operability of the pressure switches. Thus, this mode of operation required the inclusion of the pressure interlocks in the Technical Specification to demonstrate operability of the AFW system.
Following the June 9, 1985 loss of feedwater event the design of the 6" main steam line pipir.g to the AFPTs was revised. With the revised system configuration the steam lines are always maintained in a pressurized hot condition. In this configuration the AFPT steam inlet pressure switches will be in the normal state (high pressure) unless the steam line pressure at the pressure switches drops below the setpoint. In addition to isolating the steam lines, a low pressure condition at the pressure switches will also actuate an alarm in the control room to alert the operator of this condition. Thus, during power operation the operator will become aware of any failures of this interlock that render the AFW system inoperable by closing the steam isolation valves (MS106A or MS107A) due to the interlocks alarming in the control room. Thus, periodic verification of operability of this interlock is no longer required to demonstrate operability of the AFW System.
A failure of these switches in the normal state (high pressure) will affect the environmental qualification of equipment in the Auxiliary Building in the event of a HELB in the 6" AFPT steam line. The analyses submitted to the NRC in the Davis-Besse Course of Action document (Reference 1) evaluated the environmental conditions resulting from the postulated ruptures in this steam piping. These analyses (Reference 2) assumed that the pressure switches will detect the breaks and actuate an alarm in the control room to alert the operator. These analyses assumed a limiting single failure of the open main steam isolation valve (MS106A or MS107A) to close. The Auxiliary Building environmental conditions were determined using the assumption that within ten minutes of detection of the break the control room operator takes necessary manual actions to terminate the steam blowdown to the Auxiliary Building. Without the actuation of low pressure alarms in the control room to alert the operator, the steam blowdown to the Auxiliary Building will not be terminated as quickly. Extended steam blowdown could cause equipment failures due to the generation of more severe temperature environment in the Auxiliary Building than was assumed as part of the Environmental Qualification (EQ) Program. For the above reasons, the pressure switches and the alarm functions will be retained in the plant configuration.
However, as stated in the preceding paragraph operability of this interlock is not required to demonstrate operability of the AFW system.
i
- Dock;t Ns. 50-346 License No. NPF-3 Serial No. 1377 Attachment 2 Page 4 Based on the above it is concluded that the Surveillance Requirement in the Technical Specification to demonstrate AFPT steam inlet pressure interlock operability is not applicable to AFW System operability verification and it can be deleted from the Technical Specifications.
Since the Davis-Besse EQ Program takes credit for these pressure switches to alarm in the control room, administrative controls will be established to require that operability of the pressure switches be verified at least once per 31 days. These administrative controls will also require that channel calibration be performed at least once per 18 months. This will assure that the environmental conditions assumed in the EQ Program will not be exceeded due to postulated piping failures in the AFPT steam inlet lines.
The Bases to Technical Specification 3/4.7.1.2 are not affected by this proposed change.
SIGNIFICANT HAZARDS CONSIDERATION The proposed change does not involve a significant hazards consideration because the operation of the Davis-Besse Nuclear Power Station, Unit No.
1 in accordance with this change would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated because this change does not involve a modification to a system or a component. With the present configuration of the 6" main steam lines to the AFPT the periodic verification of operability of this low pressure interlock is not required to assure operability of the AFW system. Although this action deletes the Surveillance Requirement from the Technical Speci-fications, administrative controls will be established to require that operability of the pressure switches be verified at least once per 31 days and channel calibration be performed at least once per 18 months. This will assure that the environmental conditions assumed in the qualification of electrical equipment are not exceeded during postulated accident conditions. The NRC has reviewed the new HELB analyses which did not take credit for the automatic isolation of AFPT steam line and concluded that the results are acceptable (Log No. 1997 dated June 10, 1986) (10CFR50.92(c)(1)).
- 2. Create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed change does not involve modification to any plant system or equipment and does not alter the performance of actual testing in the plant for any equipment (10CFR50.92 (c) (2)) .
- 3. Involve a significant reduction in a margin of safety because the proposed change as demonstrated does not affect the AFW system oper-ability (10CFR50.92(c)(3)).
-Dock t Ns. 50-346.
, .; . License No. NPF-3~
Serial No.e1377-
, ~ Attachment 2 Page-5 -
CONCLUSION-3 0n.the basis of the above, Toledo Edison has determined that the
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Amendment Request'does not involve a significant hazards consideration.
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