Text

Proposed Tech Spec Section 3.4, Steam & Power Conversion Sys
	ML20195F770
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Site:	Rancho Seco
Issue date:	11/18/1988
From:	; SACRAMENTO MUNICIPAL UTILITY DISTRICT
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ML20195F767	List: ML20195F764; ML20195F770;
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L Attachment I Technical Specification Pages Affected by Proposed Amendment No. 170, Rev. 1 Insertion / Removal Instructions Remove Insert 2-23 3-23 3-23a 3-23a 3-23b (new page) 3-24 3-24 3-24a 3-24a 4-39 4 39 4-39a 4-39a

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation 3.4 STEAM AND POWER CONVERSION SYSTEM Applicability Applies to the operability of the turbine cycle during normal operation and for the removal of decay heat.

Obiecti u To specify minimum conditions of the turbine cycle equipment necessary to assure the required steam relief capacity during normal operation and the capability to remove decay heat from the reactor core.

5 SPElf_iRt10D 3.4.1 The reactor coolant system shall not be brought or remain above 280'F through HOT SHUT 00HN when irrediated fuel is in the pressure vessel unless the following conditions are met:

A.

Capability to remove decay heat by use of two steam generators as speci fied in 3.1.1.2. A.

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B.

One atmspheric dump valve per steam generator shall be operable, j

C.

A minimum of 250,000 gallons of water shall be available in the condensate storage tank.

4 D.

Two main steam system safety valves are operable per steam generator, i

E.

Both auxiliary feedwater pumps are operable and both cross tie valves (HV-31826 and HV-31827) are operable and four ficw paths which include the following valve groups:

Flow path #1 - FV-20527 & HV-20581 Flow path #2 - FV-20531 & HV-20577 Flow path #3 - FV-20532 & HV-20502 i

Flow path #4 - FV-20528 & HV-20578 l

are operable except that:

I Flow path #1 08 #2 may be inoperable and flow path #3 0B #4 may be inoperable.

F.

Both trains of main feedwater isolation on each main feedwater line are operable.

G.

Four independent backup instrument air bottle supply systems for l

ADVs, and MFH (including HFH startup valves) and AFH valves are operable.

Hith less than the above required components operable, be on decay heat cooling within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

Proposed Amendment No. 93, 170, Rev. 1 3-23

.i RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation 3.4.2 The reactor shall not enter or remain ir. the STARTUP through POWER OPERATION mon unless the following conditions are met:

A.

Capability to remove decay heat by use of two steam generators as specified in 3.1.1.2.

B.

One atmospheric dump valve per steam generator shall be operable except that: (1) with only one atmospheric dump valve operable, restore an inoperable valve for the other steam generator within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in hot s:iutdown within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat cooling within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; (2) with no atmospheric dump valves operable, restore at least one inoperable valve within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in hot shutdown within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat cooling within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

C.

A minimum of 250,000 gallons of water shall be available in the condensate storage tank except that with less than the minimum volume, restore the minimum volume within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in hot shutdown within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat coo 11r.9 within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

1 0.

Seventeen of the eighteen main steam safety valves are operable l

except that with less than the minimum number of valvas, restore the inoperable valve (s) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in hot shutdown f

within the naxt 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat cooling within the next l

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

E.

Four turbine throttle stop valves are operable except that with less than the minimum number of valves, restore the inoperable valve (s) within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or be in hot shutdown within tha next 5 i

hours and on decay heat cooling within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , i

e F.

Both aux 111ar3 faedwater pumps are operable and both cross tie valves (HV-31826 and HV-31827) are operable and four flow paths which include the following valve groups:

Flow path #1 - FV-20527 & HV-20581 Flow path #2 - FV-20531 & HV-20577 Flow path #3 - FV-20532 & HV-20582 Flow path #4 - FV-20528 & HV-20578 are operable except that:

(1) Hith one auxiliarv feedwater pump inoperable 03 both flow paths #1 and #2 inoperable 08 both flow paths #3 and #4 inoperable, restore to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in hot shutdown within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat cooling within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(2) Hith one or both valve (s) in a flow path inoperable, restore the inoperable valve (s) to operable within 7 days, or be in at least hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Proposed Amendment No. 93, 170, Rev. 1 3-23a

T RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation (3) Hith one or both cross. tie valve (s) inoperable, re tore to operable status or place the valve (s) in the o' a

position within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months QB be in hot shutdown wiusin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat cooling within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

l (4) Hith both auxiliary feed pumps inoperable QB more than two flow paths inoperable, the reactor shall be made suberitical within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and the reactor shall be on i

decay heat cooling within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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Proposed Amendment No. 170, Rev. 1 3 23b f

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation 3.4.2 G.

Both trains of main feedwater isolation on each main feedwater line are operable except that:

(1) Hith one main feedwater isolation train inoperable, restore the train to operable status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in hot shutdown within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat cooling within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(2) With both main feedwater isolation trains int' /racle, the reactor shall be made subcritical within fe>/ hours and the reactor shall be on decay heat cooling w.

ein the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

H.

Two independent backup instrument air bottle s..

ly systems (one l

per steamline) for ADVs are operable except that:

(1) Hith one system inoperable, restore the system to operable status within 7 days or be in hot shutdown within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat cooling within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(2) With two systems inoperable, restore at least one system within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in hot shutdown withi;i the next 6 4

hours. With one system restored to operable status within i

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , follow 3.4.2.H.(1).

k 3.

Two independent backup instrument air bottle r,upply systen (one per feedwater line) for MFW (including HFH startup valves), and AFW control valves are operable except that with either one er i

both system (s) inoperable, restora 2he inoperable system (s) 91 thin 7 days or be in hot shutdown r 'hin the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat ecoling within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Bases The feetiwater system and the turbine bypass system are normally used for decay heat removal and cooldown above 280*F. Main feedwater is supplied by operation of a condensate pump and main f edwater pump.

If neither main feed pump is available, feedwater can be supplied to the steam generators by an auxiliary feedwater pump. Steam relief capability is provided the system's atmospheric dump valves.

The auxiliary feedwater system is designed to provide sufficient flu on loss of main feedwater to match decay heat plus Reactor Coolant Pump heat occur. ")the Reactor Coolant System before solid pressurizer operation could input 19 Proposed Amendment No. 31, 87, 93, 170, Rev. 1 3-24

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation The 250,000 gallons of water in the condensate storage tank is sufficient to remove decay heat 'plus Reactor Coolant pump heat for two pumps) for

.pproximately 13 hocrs. This volume provides sufficient water to remove the decay heat for approximately 5.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months and to subsequently cool the plant to the DHR system pressure at a cooldown rate of 50'F/hr (1).

t The minimum relief capacity of seventeen steam system safety valves is 13,329,163 lb/hr.(2> This is sufficient capacity to protect t system under the design overpower condition of 112 percent.t3)he steam I

Both trains of main feedwater isolation on each main feedwater line are required to be operable.

Train A of main feedwater isolation is comprised i

of main feedwater control valves, main feedwater block valves and startup I

control valves.

Train 8 of main feedwater isolation is comprised of the main feedwater isolation valves.

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Four independent Class 1 backup air supply systems are provided to assure j

power available to certain air operated valves in the event of the loss of j

normal air supply. One system supplies power for the HFW, (including HFH startup valve), and AFH control valves feeding the "A" OTSG; another system supplies power for same valves feeding the "B" 0TSG.

Two systems supply i

power for ADVs with one for the ADVs en the "A" main steam line and one for the ADVs on the "B" main steam line.

Each systen is sized to provide at least two hours of air supply.

REFERENCES (1) B and H Occument 32-1141727-00, "Heat Pemoval Capability cf SMC CST," Harch 1984.

(2) USAR paragraph 10.3.4 1

(3) USAR Appendix 3A, Answer to Question 3A.5 i

(4) B and H Calculation 86-1167930, "Rancho Soco: AFH Hinimum Flow i

Analysis " (SHUD Calculation No. Z-FHS 10150) j i;

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t Proposed Amendment No. 31, 81, 93, 170, Rev. 1 3-24a

RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS

("rn.illance Standards 4.8 AUXILIARY FEE 0 HATER PUMP PERIODIC TESUXG Apolicability Applies to ti: periodic testing of the turbine and motor driven auxiliary feedwater pumps.

Objective To verify that the auxiliary feedwater pump and associated valves are operable.

Specification 4.8.1 Monthly on a staggered test basis at a time when the average Reactor Coolant System temperature is 1280*F, the turbir.e/ motor driven and motor driven auxiliary feedwater pumps shall be operated on recirculation to verify proper operation.

Separate tests will be performed in order to verify the turbine driven capability and the motor driven capability cf auxiliary feedwater pump P-31F The monthly test frequency rewirement rhall ba brough': current within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after the average Reactor Coolant System temperature is 2280'F for the irctor driven pumos.

The turbine drisea capability shall bo brought current within 72 heurs of obtaining 5 percert reactor power.

Acceptable performance will be indicated if the pump starts and oparates for fifteen minutes at a flow rate sufficient to assure 475 gpm of flow to the steam generator at a ditcharge pressure sufficient to drive that flow through the most restrictive flow path to a single steam generator which is at a pressure of 1050 psig.

The monthly testing of the auxiliary feedwater pumps and valves shall be performed in accordance with the inservice inspection requirements of Specification 4.2.2.1.

4.8.2 At least once per 18 months:

1.

Verify that each automatic valve in the flow path actuates to its correct position upon receipt cf each auxiliary feedwater actuation test signal.

2.

Verify that each auxiliary feedwater pump starts as designed automatically upon recaipt of each auxiliary feedwater actuation test signal.

4.8.3 Honthly, when the averag' r.ector Coolant System temperature is 1280'F, all auxiliary fer.,-

er system valves in the flow path that are not locked, sealed, or otherwise secured in position are to be inspected to verify they are in the proper position.

Proposed Amendment No. 31, 7f,, 20, 93, 170, Rev. 1 4-39

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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Surveillance Standards 44.4 Following maintenance or surveillances performed pursuant to Specifications 4.8.1, 4.8.2, and 4.8.5, those auxiliary feedwater valves manipulated in the performance of the maintenance or surveillance shall be verified to be in the proper position.

4.8.5 Prior to startup following a refueling shutdown, conduct a test to demonstrate that the motor-driven AFH pumps can pump water from the CST to the steam generator, ilAiti I

t The monthly test frequency will be sufficient to verify that the turbine / mot':r driven and motor driven auxiliary feedwater pumps are operable. Verification of correct operation will be made both from the control roon instrumentation and direct visual observation of the pumps, t

The OPER/BILTTY of the auxiliary feedwater system ensures that the Rea': tor Coolant Syst(m can be cooled down to less than 305'F from normal operating conditions ir,the event of a total loss of off-site power.

t Valves which are manipuisted for maintenance or the performance of l

surveillances will be verified to be returnad to the proper position upon j

their returr,to service.

This provides a high confidence of A7H system i

operability and e.1hances the reliability of the AFH system by augmenting the r

periodic valve position verificatior..

The electric driven auxiliary feedwater pumps are capable of delivering a total feedwater flow of 475 gpm at a pressure of 1050 psig to the entrance of the steam generators. The steam driven auxiliary feedwater pump is capable of delivering a total feedwatst flow of 475 gpm to the entrance of a

the steam generators over the steam generator operating range of 800 psig to 1050 psig.

This capacity is utilized as analytical inout to the loss of Haid Feedwater Analysis which is the design basis event for AFH flow requirements.

Proposed Amendment No. 31, 76, 80, 93, 170, Rev. 1 4-39a

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r Safety Analysis Report Proposed Amendmen: No. 170, Rev. 1 Page 1 of 6 SAFETY ANALYSIS REPORT Description of Chance Proposed Amendment No. 170, Rev. 1 clarifies the reactor operating conditions in which Technical Specifications (TS) 3.4.1 andJ.4.2appgy.

In TS 3.4.1, tho term "above 280 F is expanded to "above 2PO F thrcagh HOT SHUTDOWN" to place an upper boundary on the modes in which this specification applies.

In TS 3.4.2,

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the term "remain critical" is replaced with "in the STARTUP i

through POWER OPERATION mode" to clarify the applicable operating conditions, Proposed Amendment No. 170, Rev. 1 clarifies the definition of "Both auxiliary feedwater trains..." in TS 3.4.1.E. and 3.4.2.F.,

which specify the operability requirements of the Auxiliary Feed-water (AFW) System.

The zaferences to "SFW" (Startup Feedwater) are changed in Specifications 3.4.1.G. and 3.4.2.I. to reflect the fact that the startup valves are part of the Main Feadwater (MFW) System.

The Proposed Amendment deletes the e,rds "to the condenser" from Specification 4.8.1 (first paragraph) to reflect alternado flow paths available for AFW pump testing.

Also in Spscification 4.8.1, tha reactor coolant system avarage temparature,bove which 0

the AFW system is to be testod is enanged to 780 F.

Proposed Amendment No. 170, Rev. 1 also revises the surveillanco requirements and frequency of vorifying the flow path of the AFW System.

Proposed TS 4.8.3 specifies that all AFW flow path valves not locked or sealed be verified monthly to ensure they are in their prcper position.

Proposed TS 4.3.4 specifies that thoso AFW valves manipulated fcr survnillance testing or main-tenance be verified upon completion of the survoillance or maintenance to ensure they are in their proper position.

Bases j

are added to support proposed TS 4.8.4.

Existing TS 4.8.4 is renumbered 4.8.5.

The requiramont in proposed TS 4.8.5 to test the AFW System following "any cold shutdown or longer than 30 days duration" is toroved.

Renapn for chancta i

The changes to TS 3.4.1 and 3.4.2 clarify the oporating candi-tions in which the Specifications are operable.

The revihaan providos an uppor boundary of applicability for TS 2.4.1 and moro clearly defines the operating modos in which the requiromonts of 3

TS 3.4.2 apply.

Safety Analysis Report Proposed Amendment No. 170, Rev. 1 Page 2 of 6 The revition to the definition of "Both auxiliary feedwater trains..." clarifies the equipment required to constitute oper-able trains.

This Proposed Amendment will ensure periodic verification of AFW System flow path &s intended by Standard Technical Specifications l

as well as reduce the excessive amount of time which is presently opent in valve position verification.

Evaluation and Basis for Safety Analysis Systems, Subsystems, Components Affected:

Proposed Amendment No. 170, Rev. 1 affects the AFW System.

Thic system is described in USAR Section 10.2.2.2, Auxiliary Feedwater Supply.

The requirements for the AFW System are given in TS 3.4, Steam and Power conversion System, and TS 4.8, Auxiliary Feed-water Pump Periodic Testing.

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Safety Functions of Affected Systems / Components:

I The AFW System assuret an adequate feedwater supply to the NSSS steam generators to remove reactor decay heat during periods when i

the normal feedwater supply and/or the electrical aupply to vital

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auxiliaries has been lost.

The pumps are actuated automatically l

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upon indication of low main feedwater pump discharge pressure and/or loss of all reactor coolant pumps or safety Features Actu-l ation System (USAR Section 10.2.2.2,..

I The bases for the AFW System are to provide sufficient flow on loss of main feedwater to match decay heat plus reactor coolant

)

pump heat 4.nput to the Reactor coolant System (RCS) before solid pressurizer operation could occur (TS 3.4 Bases).

The operabil-ity of the AFW System ensures that the RCS can be cocied down to less than 305 F from normal optrating conditions in the event of a total loss of off-site power (TS 4.8 Bases).

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Effects on Safety Functiora/ Analysis of Effectn on Eafety Functionst l

It is intended that TS 3.4.1 and 3.4.2 be separate specifications with non-overlapping applicabilities.

TS 3.4.1 lists require-0 j

ments for the Steam and Power Conversion Systems from 280 F

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l through Hot Shutdown; TS 3.'.

2 lists requirements from Startup i

through Power Operation.

Due to the fact that at least one rode j

change is required to go from the conditions described in T3 j

3.4.1 to those deccrjeed in TS 3.4.2 (from Hot Shutdown to Start-up), it iu clear that evolving plant configurations souetimes j

require different actions.

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Safety Analysis Report Proposed Amendment No. 170, Rev. 1 Page 3 of 6 Existing TS 3.4 defines AFW trains as pumps and flow path (s).

The actual flow path may be unclear due to the redundancy inher-ent in the AFW System.

The proposed definition specifies an AFW pump (P-318 or P-319) and a flow path to each steam generetor (E-205 A or B).

This presents the following possible flow paths Steam generator At Through valves TV-20527 and NV-20581 2I through valves TV-20531 and NV-20577.

Steam generator B Through valves FV-20532 and NV-20502 EI through valves TV-20528 and NV-20578.

Proposed TS 3.4.1.E. requires both AFW pumps, both cross tie valves, and at least one of the tvo flow paths to each steam gen-J erator to be operable to bring the RCS to 280 F to Hot Shutdown.

This requirement is consistent with existing Technical Specifica-tions.

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Although the "SFW valves" do have a backup instrument air bottle I

supply, they are not a separate system, but part of the MFW Sys-tem.

This change clarifies the misleading references to "SFW" Ly i

referring to them as "MFW etartup valves" in Specifications I

3.4.1.G.,

3.4.2.I.,

and in the Bases for Specification 3.4.

Proposed TS 3.4.2.F. does not allow the reactor to be brought to j

or remain in the Startup through Power Operation mode unless required AFW System components are operable.

With either of the AFW pumps inoperable, or both flow paths to either steam genera-i tor inoperable, a 72-hour period is given to restore the pump /

I flow path or the plant must commence shutdown (TS 3.4.2.F.1).

This requirement ensures that at least "one pump and flow path" l

is available for each steam generator.

With both AFW pumps inop-1 erable, or more than two of the listed flow paths inoperable, tha reactor must be made suberitical within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and on decay heat l

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cooling within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (TS 3.4.2.F.4).

This require-ment ensures that extended operation will not take place without i

AFW capability.

These requirements are consistent with existing Technical Specifications.

J l-With one or both cross tie valve (s) inoperable, the valva (s) must be restored to operable status or placed in the open position within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or the plant must be in hot shutdown within the t

next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and on decay heat cooling withia the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (TS 3.4.2.F.3).

This Specificatior. recognizes that a valve may be inoperable (e.g., failure of a stroke time surveillance) and l

yet not prohibit its system from performing its intended func-l tion.

Tne cross tie valves are normally open and remain open i

during AFW System operation.

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Safety Analysis Report Proposed Amendment No. 170, Rev. 1 Page 4 of 6 With one or both valve (s) in a single flow path inoperable, ths Proposed TS directs the valves to be restored to operable status within 7 days, or be in at least hot shutdown within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

This 7-day Limiting Condition for Operation (LCO) is con-sistent with the requirements of EFIC (Emergency Feedwater Initi-ation and control) since this is mechanically comparable to having one EFIC channel inoperable.

One inoperable EFIC channel results in the same required Action (TS Table 3.5.1-1, EF:C Item 4.b, Action 1).

Prior to the installation of EFIC, the AFW Sys-tem contained Mrs valves per AFW pump-steam generator train, one SFAS and one ICS (Integrated Control System).

Only the SFAS valve was a class I valve.

In that configuration, a 3-day LCO was appropriate for the leas of operability of the Class I valve, since it effectively made the flow path inoperable (i.e., no credit could be taken for the non-Class I ICS valve).

With the installation of EFIC, other valves were installed and all valves 1

are Class I.

The loss of one valve (or even both valves in the same flow path) still provides for at least one flow path to each steam genera-tor.

In this configuration, a 7-day LCO is appropriate.

Specification 4.8.1 directs that AFW pump verification be per-formed by operating the pumps "on recirculation to the con-denser."

An alternate flow path is being installed which provides for recirculation to the Condensate Storage Tank (CST) for AFW pump testing.

Deletion of the words "to the condenser" allcws Rancho Seco the flexibility to test the AFW pumps via a flow psth from the CST to the condenser hot well, recirculation of water to the CST, or other alternate flow path.

Also in Specification 4.8.1, the RCS temperature at or above which the AFW pumps are to be tested is changed to 280 F, to be conotsw "t i

with AFW System operability requirements stated in Specification J

3.4.1.

NUREG-0103, Standard Technical Specifications for Babcock and Wilcox Pressurized Water Reactors, Section 4.7.1.2 (Survei] lance Requirenents for the Auxiliary Feedwater System) states that each AFW System be demonstrated operable at least every 31 days by:

"Verifying that each valve (manual, power-operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position."

Existing TS 4.8 requires All AFW System valves, even those that are locked, sealul, or otherwise secured in position, to be inspected following all surveillances performed pursuant to the other TS $.8 surveillances.

Safety Analysis Report Proposed Amendment No. 170, Rev. 1 Page 5 of 6 There are approximately 170 AFW System valves.

Currently, the dual verification process involves two operators and approximate-ly 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to complete.

There are at least three monthly AFW surveillances, necessitating a 4-hour verification after the com-pletion of each surveillance.

The problem is compounded during outages, when extra testing or maintenance is performed.

Proposed Amendment No. 170, Rev. 1 provides for monthly inspec-tion (when the average RCS temperature is 2280 F) of all flow 0

path valves in the AFW System which are capable of being moved without unlocking or unsecuring.

This will ensure proper valve positioning in the AFW System flow path while significantly reducing the excessive number of operations manhours spent in repetitive valve position verification.

The Proposed Amendment also provides for post-maintenance and post-testing verification of the proper positioning of those valves which were manipulated during maintenance and testing.

This ensures a return to the proper position of those AFW valves placed in an off-normal con-figuration.

The NRC performed an evaluation of AFW Systems for various oper-ating planes (NUREG-0611 and 0635).

Rancho Seco, in response to the short-term recommendations, inspects all AFW System valves including those that are locked, sealed, or otherwise secured in position, to verify they are in proper position (USAR Section 1

10.2.2.2).

Proposed Amendment No. 170, Rev. 1 ensures periodic verification of the position of ATW System flow path valves which are capable of having their position changed (valves not secured, locked, or sealed).

Administrative controls are presently in place at Rancho Seco to ensure the proper positioning of the remaining AFW System valves.

The positioning and control of locked valves is directed by Administrative Procedure OAP-0099, operations Locked valve List.

The position of all locked valves is verified prior to plant startup after leaving cold shutdown.

The correct posi-tion of all system valves is verified prior to startup of the respective system.

An administrative procedure controls the doc-umentation of the status of equipment and systems (AP.23.10, Equipment Maintenance and operating Standards).

System Lineup Alteration checklists and System Lineup Restoration checklists are used for all system lineups which vary from the position required by the applica0le procedure.

Technical Specification requirements and in-placs administrative controls ensure that all AFW System valves are in their proper position.

This ensures the capability of the AFW System to perferm its intended function.

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Safety Analysis Report Proposed Amendment No. 170, Rev. 1 Page 6 of 6 In proposed TS 4.8.5 (existing TS 4.8.4), the requirement for conducting an integrated AFW System test following all cold shut-downs longer than 30 days is removed.

Standard Technical Specifications (RUREG-0103) do not have a requirement for an integrated system test, since all ccmponnnts are periodically tested for functionality.

Monthly, th; nbility of the AFW System to establish the required flow rate it u.nonstrated and flow path valve positions are verified (TS 4.8.1 red proposed

^S 4.8.3, respectively).

The District will cont:....N te etfern an integra-r ted AFW System flow test prior to startap lowing a refueling shutdown, as required in proposed TS 4.e-Proposed Amendment No. 170, Rev. 1 provid " cenoistency with the intent of Standard Technical Specificatic a l1 'i.. riher Rancho Sec3 Technical Specifications.

the flow i v

Crix+. scion requirement for the Emergency Core Cooling

,.t em (f J.5.1.2 B.)

u demonstrates that "each valve (manual, powe sctentr-or auto-matic) in the flow path that is not locked in,isi".2on is in its normal operating position."

This verification is only required following inservice testing of pumps and valves; Proposed Amend-ment No. 170, Rev. 1 provides for more conservative, monthly verification.

1 Summary Proposed Amendment No. 170, Rev. 1 clarifies the resctor oper-ating conditions in which TS 3.4.1 and 3.4.2 apply.

It also clarifies the definition of "Both auxiliary feedwater trains..."

in TS 3.4.1.E.

and 3.4.2.F.

Proposed Amendment No. 170, Rev. 1 revises the surveillance requirements and frequency of verifying the flow path of the AFW System.

This Proposed Amendment will ensure periodic verification of AFW System flow path as intended by Standard Technical Specifications as well as reduce the exces-sive amount of time which is presently spent in valve position verification.

Proposed Amendment No. 170, Rev. 1 ensures periodic verification of the position of AFW System flow path valves which are capablo of having their position changed (valves not secured, loeked, or sealed).

Administrative controls are presently in place at Rancho Seco to ensure the proper positioning of the remaining AFW i

System valves and thus enabling the AFW System to perform its in-tended function.

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.No Significant Hazards consideration Proposed Amendment No. 170, Rev. 1 NO SIGNIFICANT HAZARDS CONSIDERATION The District has reviewed the proposed changes against each of the criterion in 10 CFR 50.92 and based on the discussion in the above safety analysis concludes:

o A significant increase in the probability cr consequerces of an accident previously evaluated in the SAR will not be created because the proposed changes to Technical Specifi-cations and in-place administrative controls ensure the proper operation of the AFW System flew path, o

The proposed changes will not create the possibility of a new or different type of accident previously evaluated in the SAR because the function of the AFW System will not be changed and the operability of the system and its ability to perform its intended function will be maintained.

o The proposed changes will not involve a significant reduc-tion in the margin of safety becausa adequate adminiutrative r

control will be maintained to ensure the operability of the j

SfW System.

Based on the above discussion, the District concludes that the proposed changes do not constituto a significant hazard to the public and in no way endanger the public's health and safety.

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ML20195F770

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