ML030560174
| ML030560174 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/24/2003 |
| From: | Colburn T NRC/NRR/DLPM/LPD1 |
| To: | Bezilla M FirstEnergy Nuclear Operating Co |
| Collins D S, NRR/DLPM, 415-1427 | |
| References | |
| TAC MB5850, TAC MB5851 | |
| Download: ML030560174 (19) | |
Text
February 24, 2003 Mr. Mark B. Bezilla Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077
SUBJECT:
BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS RE: CONTAINMENT SPRAY NOZZLE SURVEILLANCE REQUIREMENTS (TAC NOS. MB5850 AND MB5851)
Dear Mr. Bezilla:
The Commission has issued the enclosed Amendment No. 252 to Facility Operating License No. DPR-66 and Amendment No. 132 to Facility Operating License No. NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 7, 2002.
These amendments: (1) revise the surveillance frequency for air or smoke flow testing of containment spray nozzles, as specified in surveillance requirements (SRs) 4.6.2.1.d and 4.6.2.2.f, from, once per 10 years, to, following maintenance which results in the potential for nozzle blockage as determined by engineering evaluation; (2) allow the use of a visual examination in lieu of an air or smoke flow test; (3) relocate the SR 4.6.2.2.e.3 criteria for the river/service water flow rate through the recirculation spray system heat exchangers to the Updated Final Safety Analysis Report; and (4) make minor clarifying changes to the text in TS 3.3.1.1.
A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosures:
- 1. Amendment No. 252 to DPR-66
- 2. Amendment No. 132 to NPF-73
- 3. Safety Evaluation cc w/encls: See next page
February 24, 2003 Mr. Mark B. Bezilla Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077
SUBJECT:
BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS RE: CONTAINMENT SPRAY NOZZLE SURVEILLANCE REQUIREMENTS (TAC NOS. MB5850 AND MB5851)
Dear Mr. Bezilla:
The Commission has issued the enclosed Amendment No. 252 to Facility Operating License No. DPR-66 and Amendment No. 132 to Facility Operating License No. NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated August 7, 2002.
These amendments: (1) revise the surveillance frequency for air or smoke flow testing of containment spray nozzles, as specified in surveillance requirements (SRs) 4.6.2.1.d and 4.6.2.2.f, from, once per 10 years, to, following maintenance which results in the potential for nozzle blockage as determined by engineering evaluation; (2) allow the use of a visual examination in lieu of an air or smoke flow test; (3) relocate the SR 4.6.2.2.e.3 criteria for the river/service water flow rate through the recirculation spray system heat exchangers to the Updated Final Safety Analysis Report; and (4) make minor clarifying changes to the text in TS 3.3.1.1.
A copy of our safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosures:
- 1. Amendment No. 252 to DPR-66
- 2. Amendment No. 132 to NPF-73
- 3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC MO'Brien ACRS PDI-1 R/F TColburn BPlatchek, RGN-I RLobel OGC PHearn RLaufer GHill (4)
RDennig
- SE provided. No major changes made **See previous concurrence ACCESSION NO. ML030560174 OFFICE PDI-1/PM PDI-1/LA SPLB/SC RORP/SC PDI-1/SC OGC NAME TColburn**
MOBrien** SWeerakkody*,**
RDennig**
RLaufer**
RHoefling**
DATE 2/20/03 2/20/03 10/24/2002 2/21/03 2/20/03 02/20/03 OFFICIAL RECORD COPY
Beaver Valley Power Station, Units 1 and 2 Mary OReilly, Attorney FirstEnergy Nuclear Operating Company FirstEnergy Corporation 76 South Main Street Akron, OH 44308 FirstEnergy Nuclear Operating Company Regulatory Affairs/Performance Improvement Larry R. Freeland, Manager Beaver Valley Power Station Post Office Box 4, BV-A Shippingport, PA 15077 Commissioner James R. Lewis West Virginia Division of Labor 749-B, Building No. 6 Capitol Complex Charleston, WV 25305 Director, Utilities Department Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573 Director, Pennsylvania Emergency Management Agency 2605 Interstate Dr.
Harrisburg, PA 17110-9364 Ohio EPA-DERR ATTN: Zack A. Clayton Post Office Box 1049 Columbus, OH 43266-0149 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 J. H. Lash, Plant Manager (BV-IPAB)
FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077 Rich Janati, Chief Division of Nuclear Safety Bureau of Radiation Protection Deparment of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P O Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission Post Office Box 298 Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Beaver Valley Power Station ATTN: M. P. Pearson, Director Services and Projects (BV-IPAB)
Post Office Box 4 Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mr. B. F. Sepelak Post Office Box 4, BV-A Shippingport, PA 15077
PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-334 BEAVER VALLEY POWER STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 252 License No. DPR-66 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by FirstEnergy Nuclear Operating Company, et al. (the licensee), dated August 7, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-66 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 252, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 60 days. The implementation of this amendment shall include the relocation of surveillance requirement 4.6.2.2.e.3 criteria for the river/service water flow rate through the recirculation spray system heat exchangers to the Updated Final Safety Analysis Report as described in the licensees application dated August 7, 2002, and evaluated in the staffs safety evaluation attached to this amendment.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: February 24, 2003
ATTACHMENT TO LICENSE AMENDMENT NO. 252 FACILITY OPERATING LICENSE NO. DPR-66 DOCKET NO. 50-334 Replace the following pages of Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert 3/4 3-4a 3/4 3-4a 3/4 6-12 3/4 6-12 3/4 6-14 3/4 6-14
PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLEDO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-412 BEAVER VALLEY POWER STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 132 License No. NPF-73 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by FirstEnergy Nuclear Operating Company, et al. (the licensee), dated August 7, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-73 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 132, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 60 days. The implementation of this amendment shall include the relocation of surveillance requirement 4.6.2.2.e.3 criteria for the river/service water flow rate through the recirculation spray system heat exchangers to the Updated Final Safety Analysis Report as described in the licensees application dated August 7, 2002, and evaluated in the staffs safety evaluation attached to this amendment.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: February 24, 2003
ATTACHMENT TO LICENSE AMENDMENT NO. 132 FACILITY OPERATING LICENSE NO. NPF-73 DOCKET NO. 50-412 Replace the following pages of Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert 3/4 3-4a 3/4 3-4a 3/4 3-12 3/4 3-12 3/4 6-11 3/4 6-11 3/4 6-13 3/4 6-13
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 252 AND 132 TO FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLEDO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412
1.0 INTRODUCTION
By application dated August 7, 2002, the FirstEnergy Nuclear Operating Company (FENOC, the licensee), requested changes to the Technical Specifications (TSs) for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2). The licensees proposed amendments: (1) revise the surveillance frequency for air or smoke flow testing of containment spray nozzles, as specified in surveillance requirements (SRs) 4.6.2.1.d and 4.6.2.2.f, from, once per 10 years, to, following maintenance which results in the potential for nozzle blockage as determined by engineering evaluation; (2) allow the use of a visual examination in lieu of an air or smoke flow test; (3) relocate the SR 4.6.2.2.e.3 criteria for the river/service water flow rate through the recirculation spray system (RSS) heat exchangers to the Updated Final Safety Analysis Report (UFSAR); and (4) make minor clarifying changes to the text in TS 3.3.1.1.
1.1 Background
The BVPS-1 and 2 containments are reinforced concrete structures that are maintained at subatmospheric pressure during normal operation. Unmitigated release of reactor coolant into the containment during a postulated loss-of-coolant accident (LOCA), or unmitigated release of steam into containment during a postulated main steam line break (MSLB) accident, would result in substantial increases in the temperature and pressure of the internal containment atmosphere. That increased pressure would provide a driving force for leakage of fission products out of the containment.
In order to mitigate the effects of these postulated accidents and eliminate the driving potential for leakage out of the containment, the BVPS-1 and 2 engineered safety feature designs include containment depressurization systems that are used to: condense steam released inside containment; depressurize the containment below atmospheric pressure; and, maintain the containment at subatmospheric pressure for an extended period of time. These depressurization systems consist of: (1) the quench spray system (QSS), and (2) the RSS.
The QSS removes heat from, and reduces the pressure of, the containment atmosphere by spraying chilled borated water from the refueling water storage tank (RWST) into the containment atmosphere through spray nozzles that are located inside and near the top of the containment. The BVPS-1 QSS uses two redundant, 360-degree spray headers, located approximately 96 feet above the containment operating floor, that each contain 196 spray nozzles. The BVPS-2 QSS design is similar in that it utilizes two 360-degree spray headers, however, the BVPS-2 QSS uses a lower header (located 78 feet, 6 inches above the containment operating floor) that contains 120 spray nozzles, and an upper header (located 103 feet, 8 inches above the containment operating floor) that contains 39 spray nozzles. For both units, once QSS is activated following a LOCA or MSLB the water from the sprays is collected on the containment floor and it is then used to supply the RSS.
Like the QSS, the RSS cools the containment atmosphere by spraying chilled water into the containment through spray ring headers located inside and near the top of the containment.
The RSS draws water from the containment sumps, passes that water through coolers and then sprays the chilled water into the containment. Through this process, the RSS maintains the containment pressure subatmospheric and transfers the heat from the containment to the river water system (Unit 1) or the service water system (Unit 2). The BVPS-1 RSS design utilizes four, 180-degree spray headers, located approximately 80 feet above the containment operating floor, that contain a total of approximately 357 spray nozzles. The BVPS-2 RSS design uses two, 360-degree spray headers, which are located at approximately 81 feet and 84 feet above the containment operating floor, that contain a total of approximately 585 spray nozzles.
The spray ring headers for both QSS and RSS are made of corrosion-resistant stainless steel and are maintained dry at all times. In addition, the containment spray piping of interest is above the RWST water level so that it is not possible for water to enter this piping without operation of the pumps. Each QSS pump discharge line contains a weight-loaded check valve inside the containment. One-half inch drain lines are located immediately after the check valves to drain the quench spray risers should any water enter the risers during periodic testing.
Currently, SR 4.6.2.1 and SR 4.6.2.2 require periodic verification that the QSS and RSS spray nozzles are free of blockage. This verification is required to be performed once every 10 years to ensure that the QSS and RSS systems will operate as assumed in the BVPS-1 and 2 safety analyses. Additionally, the TSs require that the verification tests be performed by an air or smoke flow test to verify that the spray nozzles are not obstructed. The proposed change would modify the surveillance frequency to following maintenance which results in the potential for nozzle blockage, as determined by engineering evaluation.... BVPS-1 and 2 spray system maintenance procedures establish foreign material exclusion (FME) controls and require post-maintenance inspection to verify system cleanliness and ensure freedom from foreign material when containment spray system maintenance requires opening the system. Thus, routine maintenance activities with FME controls will not require performance of this surveillance; only unanticipated circumstances will require performance of the surveillance (such as inadvertent spray actuation or loss of foreign material control when working within the spray ring headers or risers).
In addition to the flow test with air or smoke, which may be determined to be necessary under the abnormal conditions of a failure of the FME controls or an inadvertent spray actuation, the licensee is proposing the additional option of performing a visual examination (e.g., boroscope).
The licensee also proposes to relocate the RSS flow requirement in TS 4.6.2.2.e.3 to the UFSARs for BVPS -1 and 2, respectively. The current RSS TS requires surveillance to verify a specific minimum river/service flow rate (Unit 1/Unit2, respectively) through each RSS train.
Finally, the application also proposed clarification to the test in Table 3.3-1 Reactor Trip System Instrumentation (Units 1 and 2) and Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements, (Unit 2) for the P-13 reactor trip system interlock. The change in each case is to replace the words Impulse Chamber with the words First Stage. The licensee describes the reason for this change as follows:
The proposed change to substitute the word impulse with first stage in the descriptive text associated with the P-13 function of the Reactor Trip System..does not involve any physical or design change for the P-13 function.
The proposed change is intended to eliminate any potential confusion following a future planned turbine modification when the turbine first stage will no longer be considered an impulse chamber. The future planned turbine design change to enhance the [Beaver Valley] turbines performance by making them a fully reaction turbine design (which includes the turbine first stage chamber) will not alter the current function or design of P-13.
2.0 REGULATORY EVALUATION
The General Design Criteria (GDC) of Appendix A to Title 10 of the Code of Federal Regulations (10 CFR), Part 50, are applicable to both BVPS-1 and 2. In particular, GDC 39, Inspection of containment heat removal system, requires that the containment heat removal system be designed to permit appropriate periodic inspection of important components, including spray nozzles and piping, to ensure the capability of the system.
In addition, the TSs of BVPS-1 and 2 require flow tests as the means of ensuring that the spray nozzles can accomplish their safety function. The current frequency is at least every 10 years and the flow tests must use air flow or smoke flow.
The NRC staff reviews proposed changes to TSs for compliance with 10 CFR 50.36 and agreement with the precedent as established in NUREG-1431, Revision 2, Standard Technical Specifications Westinghouse Plants, dated October 10, 2001, to determine whether or not proposed changes maintain adequate safety. Changes that result in relaxation (less restrictive condition) of current TS requirements require detailed justification.
In this amendment the licensee is modifying the containment spray nozzle surveillance frequency to improve the capability for preventing blockages in the spray nozzles. In determining the acceptability of such changes, the NRC staff reviewed the supporting analysis and the generically approved guidance of the improved standard technical specifications. For this review the NRC staff used NUREG-1431, Revision 2. This NUREG incorporates the general guidance and limiting conditions for operation (LCO) scoping criteria provided by the Commissions Final Policy Statement on Technical Specification Improvement for Nuclear Power Reactors, published in the FEDERAL REGISTER on July 23, 1993 (58 FR 39132) and incorporated in 10 CFR 50.36 effective August 18, 1995.
Licensees may revise their TSs provided that a plant-specific review supports a finding of continued adequate safety because: (1) the change is editorial, administrative or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensees current requirement, or (3) the change is less restrictive than the licensees current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 3.0 in the context of specific proposed changes.
Revising the containment spray nozzle TS surveillance frequency for the BVPS-1 and 2 is consistent with the approved TS Amendment 113, dated June 29, 2000, for the Perry Nuclear Plant, Unit 1.
3.0 TECHNICAL EVALUATION
3.1 Revision to Quench Spray and Recirculation Spray System Nozzle SRs The application describes the motivation for requesting a change to the QSS and RSS SRs: (1) the air flow tests impact fuel movement in containment, (2) the SR presents a personnel safety risk for the individuals required to access the top of containment to check the air flow through the nozzles, (3) performance of the SR is expensive, and (4) operating experience has demonstrated that nozzle blockage is predominantly associated with maintenance activities.
The licensee is, therefore, proposing to change the surveillance frequency to those conditions following maintenance which could result in nozzle blockage. The licensee is also proposing that the verification could consist of a visual inspection of the nozzles in lieu of an air or smoke test.
Demonstrating that each spray nozzle is unobstructed provides assurance that the spray coverage of the containment, in combination with the containment cooling system, is sufficient to limit the post-accident containment pressure and temperature to less than the design values.
As part of the Nuclear Regulatory Commission (NRC) staffs review of the licensees request, the staff reviewed both the pertinent BVPS-1 and 2 operating experience and industry-wide operating experience.
3.1.1 Performance History at Beaver Valley The application stated that air flow surveillance tests were performed on the BVPS-1 QSS and RSS spray nozzles in 1980 (following a change to the current design), 1984, 1989, 1995, and 2000. These tests did not identify any blockage. Similar tests on the BVPS-2 spray nozzles in 1986 (pre-operational startup test), 1990, and 1995 likewise did not identify any blockage.
3.1.2 Industry experience and failure mechanisms Review of industry experience using the NRCs Sequence Coding and Search System for Licensee Event Reports indicates that spray systems of similar design are highly reliable (i.e.,
not susceptible to plugging). The NRC staff reviewed industry experience and found that, with a few exceptions, once tested after construction, containment spray nozzles have not been subject to blockage. There have been several exceptions. In the case of one pressurized water reactor (PWR), a chemical added to the inner surface of a spray system pipe to eliminate a corrosion problem detached and the loose material blocked some spray nozzles. Spray piping at BVPS-1 and 2 is made of corrosion-resistant stainless steel; therefore, this failure mechanism is not applicable to BVPS-1 or BVPS-2. The licensee for another PWR found debris, identified as construction debris, in the spray nozzle headers. The fraction of blockage was not significant and the sprays remained functional. That debris was found by visual observation rather than by an air flow test.
Other problems have been identified in containment spray and fire protection systems in which water leakage caused corrosion that resulted in partial blockage of spray nozzles. As described above, the BVPS-1 and 2 design effectively precludes this condition since the spray ring headers are maintained dry and are made of corrosion-resistant stainless steel.
Due to their location at the top of the containment, introduction of foreign material exterior to the headers is unlikely. Although the proposed SR frequency results in less spray nozzle testing, the licensee will perform the nozzle test directly after maintenance which is the plausible cause of nozzle blockage. Since maintenance that could introduce foreign material is the most likely cause for obstruction, testing or inspection following such maintenance would suffice to verify the systems capability to perform its safety function. Since the blockage testing and maintenance are performed before startup of the plant, the operability of the nozzles is assured during plant startup and operation.
For these reasons, the potential for nozzle obstruction is very low and, therefore, the 10-year test frequency is unnecessary. Verifying that the nozzles are not obstructed following maintenance that could introduce foreign materials internal to the spray ring headers is a more appropriate frequency. This verification would consist of an inspection of the nozzles, or an air or smoke test.
The NRC staff concludes that the design of the BVPS-1 and 2 containment spray systems and the licensees FME controls will minimize the potential for containment spray nozzle obstruction.
Based on this conclusion, we find that the licensees proposed change to the surveillance frequency of SRs 4.6.2.1.d and 4.6.2.2.f, and addition of an allowance for the use of a visual examination in place of an air or smoke flow test are acceptable.
3.1.3 Regulatory Commitment In the August 7, 2002, application, FENOC committed to establish procedural controls that, will specifically address the need for an engineering evaluation to determine whether a Containment Spray Nozzle Test is necessary to ensure that the nozzles remain unobstructed following maintenance on affected sections of the Containment Spray piping systems. The licensee further specified that this commitment will be completed prior to implementation of these amendments to the BVPS-1 and 2 licenses. The NRC staff considers the proposed action to be appropriate for ensuring continued operability of the containment spray piping systems following maintenance that might introduce, or allow to be introduced, foreign material into the containment spray piping systems.
The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitment are best provided by the licensees administrative processes, including its commitment management program. The above regulatory commitment does not warrant the creation of regulatory requirements requiring prior NRC approval of subsequent changes.
3.2 Recirculation Spray System (RSS) Flow Surveillance Requirement 3.2.1 Relocation of RSS Flow Surveillance Requirements to UFSAR Demonstrating that each RSS train will satisfy a minimum flow rate provides assurance that the recirculated spray coverage of the containment, in combination with the containment cooling system, is sufficient to limit the post-accident containment pressure and temperature to less than the design values.
The licensee proposes to relocate the RSS flow rate surveillance requirements to the BVPS-1 and 2 UFSARs. This will result in TS content that is consistent with that of NUREG-1431, Revision 2. Additionally, any future changes to the surveillance requirement flow criteria specified in the UFSARs will be controlled and evaluated in accordance with the requirements of 10 CFR 50.59.
3.2.2 Regulatory Commitment In the application, FENOC committed to, perform a test on a once per 18 month frequency (+/-
25%) to verify acceptable flow rate of the river/service water through the Recirculation Spray System heat exchangers at BVPS Unit No. 1 and No. 2. The NRC staff considers the proposed action to be an acceptable method for ensuring continued operability of the RSS.
The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitment is best provided by the licensees administrative processes, including its commitment management program.
The above regulatory commitment does not warrant the creation of regulatory requirements requiring prior NRC approval of subsequent changes.
3.3 Wording Changes to the P-13 Function of the Reactor Protection System (RPS)
The requirement for the P-13 reactor trip system interlock within the RPS design is that the P-13 signal be representative of overall turbine power. This is accomplished by measuring the turbine first stage pressure since turbine first stage pressure exhibits a consistent and accurate relationship with overall turbine power. The term impulse refers to a particular type of turbine blade design. In the future the licensee could install reaction turbine blades in the first stage.
Hence, the proposed TS change is to replace the words Impulse Chamber with the words First Stage, which results in text that states the basic P-13 requirement generically, without specifying a particular turbine blade design. This TS change allows flexibility for potential future turbine design enhancements. The NRC staff agrees that this proposed change in the description of the BVPS-1 and 2 turbines does not involve any physical or design change for the P-13 function, and will have no effect on the operation of the RPS. Therefore, the NRC staff concludes that the licensees proposed revision is acceptable since it results in a TS that is generic for turbine blade design and retains the required P-13 safety function.
3.4 Summary of NRC staff Conclusions The staff reviewed the proposed changes for compliance with 10 CFR 50.36 and GDC 39.
Additionally, the NRC staff reviewed plant-specific and industry performance history as described above, and the design of the BVPS-1 and 2 QSS and RSS systems. Based on its review, the NRC staff concludes that the design of the BVPS-1 and 2 containment depressurization systems, combined with the licensees FME program to address nozzle blockage when performing maintenance on the system, will minimize the potential for nozzle blockage. The NRC staff, therefore, concludes that the licensees proposed TS change, which modifies the frequency of verifying the QSS and RSS nozzles are unobstructed from once every 10 years to conditions following maintenance which could result in nozzle blockage, is acceptable. The NRC staff also finds addition of a provision to perform visual inspections in lieu of air or smoke flow tests to be acceptable. Additionally, the NRC staff concludes that relocation of the RSS flow rate surveillance requirements to the BVPS-1 and 2 UFSARs is acceptable. Finally, the NRC staff concludes that the proposed change in the description of the turbine in the TSs dealing with the P-13 interlock has no effect on the reactor protection system and is also acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (67 FR 63694). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: R. Lobel P. Hearn D. Collins Date: February 24, 2003