ML20211A319

Proposed Tech Specs Re Pressure Differential Surveillance Requirements for Containment Spray Pumps

ML20211A319
Person / Time
Site:	Sequoyah
Issue date:	09/17/1997
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20211A313	List: ML20211A309 ML20211A319
References
CON-TVA-SQN-TS-97-02, CON-TVA-SQN-TS-97-2, RTR-NUREG-1431 NUDOCS 9709240214
Download: ML20211A319 (11)

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l ENCLOSURE 1 TENNESSk:E VALLEY AUTilORITY SEQUOYAll NUCLEAR PLANT (SQN)

UNITS 1 AND 2 DOCKET NOS 50-327 AND 50-320 PROPOSED TECilNICAL SPECIFICATION (TS) CHANGE T0-97-02 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE

1. DESCRIPTION OF Tile PROPOSED CHANGE TVA proposes to modify the SON Units 1 and 2 TSs to revise Surveillance hequirement (SR) 4.6.2.1.1.b. This revision will replace the specific containment spray pump differential pressure requirements with new requirements that allow testing based on required developed head.

Additional changes are proposed to Surveillances 4.6.2.1.1.c, 4.6.2.1.1.d, and 4.6.2.1.2.b to provide consistency with the Standard TS, NUREG-1431.

These changes are as follows:

• SR 4.6.2.1.1.b - Replace the current pump verification requirements that prescribe a specific differential pressure at a minimum flow rate with a requirement to verif y that the pump's developed head at the flow test point is greater than or equal to the required developed head.

• SR 4.6.2.1.1.c - Delete the requirement for the 18-month surveillance to be performed "during shutdown."

• SR 4.6.2.1.1.c.1 - Add the clarification that only automatic valves that are not locked, sealed, or otherwise secured in position are applicable, e SR 4.6.2.1.1.c.1 and .2 - Replace the specific actuation test signal with the requirement to verify the function on an actual or simulated actuation signal.

• SR 4.6.2.1.1.d and 4.6.2.1.2.b - Delete the specific method for verifying spray nozzles are unobstructed.

II. REASON FOR THE PROPOSED CHANGE TVA installed flow orifices in the containment spray flow paths in 1991 te prevent excessive flows that could result in damage to the pumps. This change provided limited flow conditions to prevent the potential to create a pump air ingestion condition during switch over from the refueling 9709240214 970917 El-1 PDR ADOCK 05000327 p PDR

water storage tank to the containment sump. The

' processing of the modification failed to identify the impact to TS requirements; however, proper performance of the containment spray pumps has been verified with the l higher required developed head. This revision to the SQN l TSs will provide the appropriate requirements to accommodate the new developed head limits.

The other changes proposed by this request are included to provide consistency with the latest version of Standard TS (NUREG-1431) and to incorporate the flexibility provided by the NUREG. These changes do not alter the intent of the TS.

III. S_AFETY ANALYSIS The current TS requirements are not conservative with respect to the required containment spray pump pressure differential after modification of the flow orifices. The proposed change will require the pumps to perform at the required developed head regardless of changes to the system that result in changes to this value. This revision will require the pumps to perform at the appropriate limits for operability and plant procedures have been implemented to meet this requirement. This change accommodates the new developed head requirements for the containment spray pumps but does not alter the intent of this surveillance.

The remaining changes in this request are not initiated as a result of any change to the plant or to revise the intent of the TS requirements. These changes are proposed to implement requirements that are consistent with NUREG-1431.

The deletion of the "during shutdown" provision of the 18-month surveillances will continue to require the current frequency for these tests based on engineering judgment and operating experience and accommodates the performance of surveillances that require outage conditions. Deleting the "during shutdown" portion of these requirements will not affect performance of surveillances that require shutdown conditions but will provide the flexibility to perform those portions that do not require a unit shutdown.

The exclusion for automatic valves that are locked, sealed, or otherwise secured, with regard to the actuation test, has been added to clarify that valves administratively controlled in the required position do not require the actuation test. Since these valves are administrative 1y controlled in the required position for accident mitigation, there is no benefit in performing this surveillance. This change will also provide El-2

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l consistency with Surveillance 4.6.2.1.1.a that verifies

' containment spray valves to be in the correct position with this same exclusion.

The revision for the containment pressure high-high test signal to be changed to an actual or simulated actuation signal does not alter the requirement such that the current source of the actuation signal can not be used.

The current requirement limits the type of actuation signal to a simulated test signal and does not have a provision for the use of an actual signal. The proposed change will allow the flexibility to use an actual signal for this actuation consistent with the NUREG wording.

The deletion of the specific method for verifying that spray. nozzles are unobstructed will not change the intent of these surveillances. TVA will cont 3nue to verify the spray nozzles are open and available to provide flow; however, the method used for this verification does not need to be delineated in the TSs. This change will not alter the current verification method but will allow the technique to be changed if other appropriate methods are discovered that will meet the intent of the surveillances.

These revisions are consistent with NUREG-1431 and are implemented to provide flexibility without changing the intent of the TS requirements.

IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that operation of SON Units 1 and 2 in accordance with the proposed change to the TSs does not involve a significant hazards consideration. TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50. 91 (a) (1) , of the three standards set forth in 10 CFR 50. 92 (c) .

A. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed revisions to the containment spray system surveillances for the pumps, valves, and nozzles do not change the intent of the current TS requirements. Tnese revisions only affect the TS operability testing requirements without changing the system functions. These functions are not considered to be accident initiators. The proposed surveillance wording is not based on changes to the plant although a modification to flow orifices for the containment spray pumps created the need to revise the surveillance that verifies pump developed head. The revisions primarily provide flexibility for required methods to verify system operability as well as El-3

utilizing less prescriptive operability limits and conditions for testing. The testing flexibility and less prescriptive requirements do not relax the intent to properly verify operability of the containment spray system but do allow for changes in testing that continue to ensure the appropriate operability requirements. Since these revisions are not directly related to modifications of the plant or result in different methods for operating the plant, there is no change that could increase the probability of an accident. In addition, the consequences of an accident are not increased because there has not been a change that would impact the safety functions of the containment spray system. l These revisions will continue to properly verify the  ;

I operability of the containment spray system.

B, The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The containment spray system functions are not changed as discussed above and the operating practices for the plant remain the same. The testing methods can be modified as a result of the proposed revisions but will continue to maintain appropriate verifications of system operability. These testing methods as well as the containment spray system are not considered to be a potential initiator of accidents. Therefore, these revisions will not impact the operation of systems that could initiate an accident and the possibility of a new or different kind of accident is not created.

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l C. The proposed amendment does not involve a significant reduction in a margin of safety.

! The proposed revisions do not directly change the l limits for containment spray system operability l although they do provide the flexibility to properly revise limits resulting from system modifications.

i i This type of limit revision would be necessary to adequately verify system operability. The appropriate limits continue to be required by the proposed TS surveillance requirements. Therefore, the proposed revisions do not allow inappropriate changes to setpoints or operating requirements that maintain the margin of safety and no reduction in l this margin is involved in this request.

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'V. tNVIRONMENTAL IMPACT CONSIDERATIg The proposed change does not involve a significant hazards consideration, a significant change in the types of or significant increase in the amounts of any offluents that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure. l Therefore, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) . Therefore, pursuant to 10 CPR 51.22(b), an environmental assessment of the proposed chango is not required.

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ENCICSURE 2 TENNESSEE VALLEY AUTHORITY ,

SEQUOYAH PLANT (SQN)

UNIT 8 1 AND 2 PROPOSED TECHNICAL 8PECIFICATION (TS) CHANGE T8-97-02 MARKED PAGES I. AFFECTED PAGE LIST-i Unit 1 ,

N 6-16a ,

Unit 2 4 6-16a II. MARKED PAGES See attached.

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CURVEILLANCE REQUIREMENTS (Continued)[

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b. By verifying, that en ree&**ulo ien fler, :: h p ; dev:1:; :

444f er:ntial-preeeuce-ef-treeter th:n :r : ;;;1-tc 143 p;;id :t - ,

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c. At lea t'o per 18 months durir; thuid:^.r, y:

1. Verifying that each automatic valve in the flow path actuates j nttinn nt Pr:::ur: "igh "ich-to its correct t::; i;- position Q on anNML bd S/*WAM7FD NCTHMrHAl$/MALs n_

2. Veri ying that each spray

: n t : . ::nt r :::ur: " pump starts automatically on.a-i;.. "i;h t :t signal, hl AtlNAL 02 SIMRLAND /fCTunTMAI

d. At least once per 10 years by perferr!n; en air er erthe !!:: test ( [222  !

th.;;# :::h :pr:y '::d:: :n' ' in each spray nozzle is f

+ unobstructed. .

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R73 4.6.2.1.2 Each RHR spray train shall be demonstrated OPERABLE:

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a. Per surveillance requirements 4.5.2.b.2 and 4.5.2.f.3 r

, b. At least once per 10 years Ey pt:ferrin; en 21: :: r ch: f 1:- lR222 t::t through :: h spr:y h::d r :nd vev44y&ney each spray nozzle i R73 is unobotructed.

y Nv/g'X fry b /f7 b bl07 l-0CAfDj 1 bOfLiD, 0A 07)KW10/$r bfMAfD $ ?03/ Tid /V, W _x .

February 7, 1996 SEQUOYAH - UNIT 1 3/4 6-16a Amendment No. 12, 69 80 218

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[Tstr Dex fams:s Drynefa) Hmo Ar D CONTAINMENT _ SYSTEMS Tor Row 'br Powr Is gkontt %'

SURVEILIINCEREQUIREMENTS (Continued)'k O # )

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b. By verifying that en :*sivoulatten flee, each p ; develepe -

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c. At least once per ud , by:

1. Verifying that each automatic valve in the flow pathfactuates to )

" tci unt Pr:::ue- "igh-High t: t its correct position on -: N:iML abynsa, A4' $4 SwetaAM1? k'YHMT/#AlS/$.4/JLo I

2. l Verifying

" nt that each spray: "i pump starts "4gh t::t 04 9automatically nal. on p/vderaw, ON $'m. T: t P eneur:ts44M7FD krNMTMrl fN4Le &g.

d. At least once por 10 years by p::f:=d:g n-air-.-or creke flee tert lR208 ,

-threr;F each pray 4eader-and-veeld each spray nozzle is 2  ?

4.6.2.1.2 Each RHR Spray train chall be demonstrated OPERABLE: R61  !

a. Per surveillance re uirements 4.5.2.b.2 and 4.5.2.f.3;

b. At least once por 10 years by performing-an air er-emeke fle" lR200

• t;;t thrcceiih ;ech spray hr.adcr-;r.d 1eraff rs -

i each spray nozzle R61 1s unobstructed. 1 stiff t

February 7, 1996 SEQUOYAH - UNIT 2 3/4 6-16a Amendment No. 61, 71, 208 p

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. l ENCLO8URE 3 TENNESSEE VALLEY AUTHORITY l SEQUOYAH NUCLEAR PLANT (8QN)

UNIT 8 1 AND 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-97-02 REVISED PAGES-

=1. AFFECTED PAGE LIST Unit'1

% 6-16a Unit 2 4 6-16a II. REVISED PAGES See attached. l e

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l CONTAINMENT SYSTEMS SURVEILLkNCEREQUIREMENTS (Continued)  !

b. By verifying that each pump's developed head at the flow test point is greater than or equal to the required developed head when tested pursuant to Specification 4.0.5. lR84

c. At least once per 18 months by:

1. Verifying that each automatic valve in the flow path that is not locked, sealed, or otherefr: secured in position, actuates to its correct position on an actual or simulated actuation signal.

2. Verifying that each spray pump starts automatically on an actual or simulated actuation signal,

d. At least once per 10 years verify each spray nozzle is unobstructed.

4.6.2.1.2 Each RHR spray train shall be demonstrated OPERABLE: R73

n. Per surveillance roquirements 4.5.2.b.2 and 4.5.2.f.3s

b. At least once per 10 years verify each spray nozzle is

.nobstructed.

SEQUOYAH - UNIT 1 3/4 6-16a Amendment No. 12, 69, 00, 218, m AIsyy -e g , c- ----g -- w +y- +-- --> er w ----wg ymyie4.p= g

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(T>NTAINMENT SYSTEMS SURk'EILI NCE REQUIREMENTS (Continued)

b. By verifying that each pump's developed head at the flow test point is greater than or equal to the required developed head when tested pursuant to specification 4.0.5. lR71

c. At least once per 18 months by:

1. Verifying-that each automatic valve in the flow path that is not locked, sealed, or otherwice secured in position, actuates to its correct position on an actual or simulated actuation signal.

2. - Verifying that each spray pump starts automatically on an actual or simulated actuation signal,

d. At least once per 10 years verify each spray nozzle is unobstructed.

4.6.2.1.2 Each RHR spray train shall be demonstrated OPERABLE: R61

a. Per surveillance requirements 4.5.2.b 2 and 4.5.2.f.3;

b. - At least once per 10 years verify each spray nozzle is unobstructed. l 3

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SEQUOYAH . UNIT 2 3/4 6-16a Amendment No. 61, 72,- 208, l

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