L-04-132, No. 2, Supplement to License Amendment Request Nos. 321 and 193

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No. 2, Supplement to License Amendment Request Nos. 321 and 193
ML042880455
Person / Time
Site: Beaver Valley
Issue date: 10/11/2004
From: Pearce L
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-04-132
Download: ML042880455 (16)


Text

FENOC Beaver Valley Power Station Route 168 PO. Box 4 FirstEnergy Nuclear Operating Company Shippingport. PA 15077-0004 L. William Pearce 724-682-5234 Site Vice President Fax: 724-643-8069 October 11, 2004 L-04-132 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Supplement to License Amendment Request Nos. 321 and 193 FirstEnergy Nuclear Operating Company (FENOC) letter L-04-040, dated March 22, 2004, submitted License Amendment Request (LAR) Nos. 321 and 193 that proposed modifying the Technical Specification requirements for mode change limitations in Specifications 3.0.4 and 4.0.4. The changes proposed in LAR 321 and 193 were prepared using the Consolidated Line Item Improvement Process (CLIIP) and were consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specifications (STS) change TSTF-359, Revision 8, as modified by the notice in the Federal Register published on April 4, 2003. FENOC letter L-04-105, dated July 23, 2004 supplemented the March 22, 2004 submittal.

During a September 28, 2004 phone call held between FENOC and the NRC, the NRC reviewer requested that the Specification 3.0.4.c allowance proposed for Technical Specifications 3.3.3.8, Accident Monitoring Instrumentation, and 3.4.6.1, Reactor Coolant System Leakage, be removed from the Beaver Valley Power Station (BVPS) submittal.

Removal of the proposed Specification 3.0.4.c allowance for the cited Technical Specifications will result in the BVPS submittal being more consistent with other TSTF-359 submittals. Removal of the LCO 3.0.4.c allowance will also ensure that plant conditions existing at the time the mode change is considered are addressed.

This letter, therefore, provides proposed revisions to Technical Specifications 3.3.3.8, Accident Monitoring Instrumentation, and 3.4.6.1, Reactor Coolant System Leakage, for both BVPS units. These pages supersede the applicable proposals that were submitted by FENOC letter L-04-040.

For completeness, proposed revisions to the applicable Technical Specifications Bases pages are also attached.

Beaver Valley Power Station, Unit Nos. 1 and 2 Supplement to License Amendment Requests 321 and 193 L-04-132 Page 2 Attachments A-1 and A-2 provide the existing pages for Technical Specifications 3.3.3.8, Accident Monitoring Instrumentation, and 3.4.6.1, Reactor Coolant System Leakage, for Unit Nos. 1 and 2, respectively, annotated to show the revised proposed changes.

Attachments B-1 and B-2 provide the applicable Technical Specifications Bases pages for Unit Nos. 1 and 2, respectively, annotated to show the revised proposed changes. The proposed Technical Specification Bases changes do not require NRC approval.

The Beaver Valley Power Station Technical Specification Bases Control Program controls the review, approval and implementation of Technical Specification Bases changes.

The Technical Specification Bases changes are provided for information only.

The proposed revisions to the cited Technical Specifications do not invalidate either the safety evaluation or no significant hazards consideration determination transmitted in FENOC letter L-04-040.

FENOC understands that receipt of the revised pages will enable the issuance of the requested amendments by October 30, 2004.

No new commitments are contained in this submittal. If there are any questions concerning this matter, please contact Mr. Henry L Hegrat, Supervisor, Licensing at 330-315-6944.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October. l 2004.

Sincerely, William Pearce Attachments:

A-1 Revised Unit No. 1 Technical Specification Changes A-2 Revised Unit No. 2 Technical Specification Changes B-1 Revised Unit No. 1 Technical Specification Bases Changes B-2 Revised Unit No. 2 Technical Specification Bases Changes c:

Mr. T. G. Colburn, NRR Senior Project Manager Mr. P. C. Cataldo, NRC Sr. Resident Inspector Mr. S. J. Collins, NRC Region I Administrator Mr. D. A. Allard, Director BRP/DEP Mr. L. E. Ryan (BRP/DEP)

Attachment A-1 Beaver Valley Power Station, Unit No. 1 Revised Technical Specification Changes License Amendment Request No. 321 The following is a list of the affected pages:

3/4 3-50 3/4 411

INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.8 The accident monitoring instrumentation channels shown in Table 3.3-11 shall be OPERABLE.

APPLICABILITY:MODES 1, 2 and 3.

ACTION:

a.

With the number of OPERABLE accident monitoring instrumentation channels less than the Total Number of Channels shown in Table 3.3-11, either restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (follow Specification 3.4.11 when determining ACTIONS for Items 5 and 6).

b.

With the number of OPERABLE accident monitoring instrumentation channels less than the Minimum Channels OPERABLE requirements of Table 3.3-11, either restore the inoperable channel(s) to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

c.

The previsiens ef Specification 3.0.4 are net applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.8 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-7.

BEAVER VALLEY -

UNIT 1 3 /4 3-50 Amendment No. 1-g4 I

REACTOR COOLANT SYSTEM 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.4.6.1 The following Reactor Coolant System leakage detection instrumentation shall be OPERABLE:

a.

One containment sump (narrow range level or discharge flow) monitor; and

b.

One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

a.

With the required containment sump monitor inoperable(),

operations may continue for up to 30 days provided that a Reactor Coolant System water inventory balance measurement (Specification 4.4.6.2.b) is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With the required containment atmosphere radioactivity monitor inoperable, operations may continue for up to 30 days provided:

1.

Grab samples of the containment atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or

2.

A Reactor Coolant System water inventory balance measurement (Specification 4.4.6.2.b) is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

(1) The preSiziz of Specification 3.0.4 are not aplieable.-

BEAVER VALLEY -

UNIT 1 3 /4 4-11 Amendment No. 189@

Attachment A-2 Beaver Valley Power Station, Unit No. 2 Revised Technical Specification Changes License Amendment Request No. 193 The following is a list of the affected pages:

3/4 3-57 3/4 4-17

INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.8 The accident monitoring instrumentation channels shown in Table 3.3-11 shall be OPERABLE.

APPLICABILITY:

MODES 1, 2 and 3.

ACTION:

a.

With the number of OPERABLE accident monitoring instrumentation channels less than the Total Number of Channels shown in Table 3.3-11, either restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (follow Specification 3.4.11 when determining ACTIONS for Items 4 and 5).

b.

With the number of OPERABLE accident monitoring instrumentation channels less than the Minimum Channels OPERABLE requirements of Table 3.3-11, either restore the inoperable channel(s) to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

c.

With the number of OPERABLE Reactor Coolant System Subcooling Margin Monitor instrumentation channels less than the Minimum Channels OPERABLE requirements of Table 3.3-11, either restore the inoperable channel(s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

d.

The proevicon_ of Speifioeatin 3.0.4 are net appe,_c.

SURVEILLANCE REQUIREMENTS 4.3.3.8 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-7.

BEAVER VALLEY -

UNIT 2 3 /4 3-57 Amendment No. -&9

REACTOR COOLANT SYSTEM 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE LEAKAGE DETECTION INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.4.6.1 The following Reactor Coolant System leakage detection instrumentation shall be OPERABLE:

a.

One containment sump (narrow range level or discharge flow) monitor; and

b.

One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

a.

With the required containment sump monitor inoperablei),

operations may continue for up to 30 days provided that a Reactor Coolant System water inventory balance measurement (Specification 4.4.6.2.b) is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b.

With the required containment atmosphere radioactivity monitor inoperable-l), operations may continue for up to 30 days provided:

1.

Grab samples of the containment atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or

2.

A Reactor Coolant System water inventory balance measurement (Specification 4.4.6.2.b) is performed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

(1) The p--evzienz of Specifieation 3.0.4 are not applieabl--e-.

BEAVER VALLEY -

UNIT 2 3 /4 4-17 Amendment No. -64 I

Attachment B-i Beaver Valley Power Station, Unit No. I Revised Technical Specification Bases Changes License Amendment Request No. 321 The following is a list of the affected pages:

B 3/4 3-3

  • B 3/4 4-3b B 3/4 4-3c
  • No changes proposed. Page included for readability.

INSTRMENTAION IProvided fr Information Only.

INSTRUMENTATION l

No changes proposed. Page included for readability.

BASES 3/4.3.3.5 REMOTE SHUTDOWN INSTRUMENTATION The OPERABILITY of the remote shutdown instrumentation ensures that sufficient capability is available to permit shutdown and maintenance of HOT STANDBY of the facility from locations outside of the control room.

This capability is required in the event control room habitability is lost and is consistent with General Design Criteria 19 of 10 CFR 50.

3/4.3.3.7 (This Specification number is not used.)

3/4.3.3.8 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables during and following an accident.

This capability is consistent with the recommendations of Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Plants to Assess Plant Conditions During and Following an Accident," December 1975 and NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations."

BEAVER VALLEY -

UNIT 1 B 3/4 3-3 Amendment No. 233

Provided for Information Only.

REACTOR COOLANT SYSTEM I

No changes proposed. Page included for readability.

BASES 3/4.4.6.1 LEAKAGE DETECTION INSTRUMENTATION (Continued)

LCO (Continued)

The LCO is satisfied when monitors of diverse measurement means are available.

Thus, the containment sump monitor, in combination with a gaseous or particulate radioactivity monitor, provides an acceptable minimum.

The containment sump monitor is comprised of the instruments associated with the non-ECCS portion of the containment sump which monitor narrow range level and sump pump discharge flow.

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is to be less than or equal to 200OF and pressure is maintained low or at atmospheric pressure.

Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller.

Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS

a.

With the required containment sump monitor inoperable, no other form of sampling can provide the equivalent information;

however, the containment atmosphere radioactivity monitoring system will provide indications of changes in leakage.

Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 4.4.6.2.b, must be performed at an increased frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide information that is adequate to detect leakage.

Restoration of the required sump monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure.

This time is acceptable, considering the frequency and adequacy of the RCS water inventory balance required by Required Action "a."

BEAVER VALLEY -

UNIT 1 B 3/4 4-3b Amendment No. 183

REACTOR COOLANT SYSTEM Provided for Information Only.

BASES 3/4.4.6.1 LEAKAGE DETECTION INSTRUMENTATION (Continued)

ACTIONS (Continued) flequ-ired Aeszien "a"l is medified by a Nete that irncieates that: tha previsiens ef LCO 3.0.~ are net applieabl.-As -a result, a ;,GEE ehange is alloe:ed ~--hcn the een~tainmcnt sump rmeniter.t i~noperable.

This alle;:anee af providod beeauseo

.;etheJ r

istrumenatien s

available te faeir

.vS leakage w.

b.l. and b.2.,

With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required.

Either grab samples of the containment atmosphere must be taken and analyzed or water inventory balances, in accordance with SR. 4.4.6.2.b, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval provides periodic information that is adequate to detect leakage.

The 30 day Completion Time recognizes at least one other form of leakage detection is available.

*JUI!

IS

a oy a

idee efnae nta ca c that thc provi _ion of LCO 3.0.4 arc not applicablc.

As a

-csult, a M-ODS chang is allooied when the gasccus and particulate contaminmnt atmoeophere radieacti-vity

=non4 tor ehanne! is irnoperable.

This allewanee +s previded beacauso C.

With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown is required.

The plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant condition from full power conditions in an orderly manner and without challenging plant systems.

BEAVER VALLEY -

UNIT 1 B 3J4 4-3c Amendment No. 1°3 1

Attachment B-2 Beaver Valley Power Station, Unit No. 2 Revised Technical Specification Bases Changes License Amendment Request No. 193 The following is a list of the affected pages:

B3/43-11

  • B 3/4 4-4b
  • B 3/4 4-4c No changes proposed. Page included for readability.

a Provided for Information Only.

3/4.3 INSTRUMENTATION No changes proposed. Page included for readability.

BASES 3/4.3.3.3 (This Specification number is not used.)

3/4.3.3.4 (This Specification number is not used.)

3/4.3.3.5 REMOTE SHUTDOWN INSTRUMENTATION The OPERABILITY of the remote shutdown instrumentation ensures that sufficient capability is available to permit shutdown and maintenance of HOT STANDBY of the facility from locations outside of the control room.

This capability is required in the event control room habitability is lost and is consistent with General Design Criteria 19 of 10 CFR 50.

3/4.3.3.6 (This Specification number is not used).

3/4.3.3.7 (This Specification number is not used).

3/4.3.3.8 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables during and following an accident.

This capability is consistent with the recommendations of Regulatory Guide 1.97, "Instrumentation for Light-Water-Cooled Nuclear Plants to Assess Plant Conditions During and Following an Accident," December 1975 and NUREG-0578, "'TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations."

BEAVER VALLEY -

UNIT 2 B 3/4 3-11 Change No. 2-008

Provided for Information Only.

REACTOR COOLANT SYSTEM 9

No changes proposed. Page included for readability.

BASES 3/4.4.6.1 LEAKAGE DETECTION INSTRUMENTATION (Continued)

LCO (Continued)

The LCO is satisfied when monitors of diverse measurement means are available.

Thus, the containment sump monitor, in combination with a gaseous or particulate radioactivity monitor, provides an acceptable minimum.

The containment sump monitor is comprised of the instruments associated with the non-ECCS portion of the containment sump which monitor narrow range level and sump pump discharge flow.

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is to be less than or equal to 200OF and pressure is maintained low or at atmospheric pressure.

Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller.

Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS

a.

With the required containment sump monitor inoperable, no other form of sampling can provide the equivalent information;

however, the containment atmosphere radioactivity monitoring system will provide indications of changes in leakage.

Together with the atmosphere monitor, the periodic surveillance for RCS water inventory balance, SR 4.4.6.2.b, must be performed at an increased frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide information that is adequate to detect leakage.

Restoration of the required sump monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure.

This time is acceptable, considering the frequency and adequacy of the RCS water inventory balance required by Required Action "a."

BEAVER VALLEY -

UNIT 2 B 3/4 4-4b Amendment No. 64

R Provided for Infortnation Only.

REACTOR COOLANT SYSTEM BASES 3/4.4.6.1 LEAKAGE DETECTION INSTRUMENTATION (Continued)

ACTIONS (Continued)

Required Action "a" is modified bhy a eote that indcicates that the pro.c-

_ons of LCD 3.0.4 arc not applicable. As a rceult, a MODE change is alloec-ed when the contain--cnt sump monitor is ineperable.

This alloe.:anec is provided because other instrumentation is available to monitor flS leakhagc.

b.1 and b.2.

With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required.

Either grab samples of the containment atmosphere must be taken and analyzed or water inventory balances, in accordance with SR 4.4.6.2.b, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval provides periodic information that is adequate to detect leakage.

The 30 day Completion Time recognizes at least one other form of leakage detection is available.

Required eaction "b" is modifie6 by a Bete that indicate_

that the provisions of LCD 3.0.4 are not applicable.

Atc a result, a MGODE change is allowed when the gaseous and particulate eentainment ateosphrc radioactivity monitor channel is inoperable.

This allewance is provided bceause other instrumentation is available to monitor for RLS LEA AGSE.

c.

With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown is required.

The plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant condition from full power conditions in an orderly manner and without challenging plant systems.

BEAVER VALLEY -

UNIT 2 B 3/4 4-4c Amendment No. -64 l