ML050600094
| ML050600094 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley (DPR-066, NPF-073) |
| Issue date: | 03/11/2005 |
| From: | Colburn T NRC/NRR/DLPM/LPD1 |
| To: | Pearce L FirstEnergy Nuclear Operating Co |
| Colburn T, NRR/DLPM, 415-1402 | |
| References | |
| TAC MC3375, TAC MC3376 | |
| Download: ML050600094 (20) | |
Text
March 11, 2005 Mr. L. William Pearce 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 (BVPS-1 AND 2) -
ISSUANCE OF AMENDMENT RE: BVPS-2 OVERPRESSURE PROTECTION SYSTEM (OPPS) ENABLE TEMPERATURE, RESIDUAL HEAT REMOVAL (RHR) SYSTEM SURVEILLANCE, AND MISCELLANEOUS AND ADMINISTRATIVE CHANGES (TAC NOS. MC3375 AND MC3376)
Dear Mr. Pearce:
The Commission has issued the enclosed Amendment No. 265 to Facility Operating License No. DPR-66 and Amendment No. 146 to Facility Operating License No. NPF-73 for BVPS-1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 1, 2004, as supplemented July 23, 2004 and February 18, 2005.
These amendments lower the BVPS-2 OPPS enable temperature, allow one inoperable RHR loop during surveillance testing, remove the TS list of figures and list of tables from the Index of the BVPS-1 TSs, and make minor changes to achieve consistency between the units and with the Standard TSs for Westinghouse plants and with some TS Task Force changes.
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. to DPR-66
- 2. Amendment No. to NPF-73
- 3. Safety Evaluation cc w/encls: See next page
Mr. L. William Pearce 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 (BVPS-1 AND 2) -
ISSUANCE OF AMENDMENT RE: BVPS-2 OVERPRESSURE PROTECTION SYSTEM (OPPS) ENABLE TEMPERATURE, RESIDUAL HEAT REMOVAL (RHR) SYSTEM SURVEILLANCE, AND MISCELLANEOUS AND ADMINISTRATIVE CHANGES (TAC NOS. MC3375 AND MC3376)
Dear Mr. Pearce:
The Commission has issued the enclosed Amendment No. 265 to Facility Operating License No. DPR-66 and Amendment No. 146 to Facility Operating License No. NPF-73 for BVPS-1 and 2. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated June 1, 2004, as supplemented July 23, 2004 and February 18, 2005.
These amendments lower the BVPS-2 OPPS enable temperature, allow one inoperable RHR loop during surveillance testing, remove the TS list of figures and list of tables from the Index of the BVPS-1 TSs, and make minor changes to achieve consistency between the units and with the Standard TSs for Westinghouse plants and with some TS Task Force changes.
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. to DPR-66
- 2. Amendment No. to NPF-73
- 3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC MO'Brien(3)
ACRS PDI-1 R/F TColburn GMatakas, RGN-I OGC RLaufer GHill (4)
TBoyce DLPM DPR DCoe VHall JUhle LLois ACCESSION NO. ML050600094
- Input provided. No substantive changes made.
OFFICE PDI-1/PM PDI-1/LA IROB/SC SRXB/SC PDI-1/SC OGC NAME TColburn MOBrien TBoyce*
JUhle*
RLaufer MYoung DATE 3/1/05 3/1/05 02/15/05 09/21/04 3/11/05 3/11/05 OFFICIAL RECORD COPY
Beaver Valley Power Station, Unit Nos. 1 and 2 cc:
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 Department 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: R. G. Mende, Director Work Management (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. 265 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 June 1, 2004, as supplemented July 23, 2004 and February 18, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's 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. 265, 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 30 days.
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: March 11, 2005
ATTACHMENT TO LICENSE AMENDMENT NO. 265 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 XVI XVII XIX 3/4 4-2b 3/4 4-2b 3/4 4-2c 3/4 4-2c 3/4 5-3 3/4 5-3 3/4 5-6 3/4 5-6
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. 146 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 June 1, 2004, as supplemented July 23, 2004 and February 18, 2005, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's 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 Commission's 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 Commission's 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. 265, 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 30 days.
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: March 11, 2005
ATTACHMENT TO LICENSE AMENDMENT NO. 146 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 4-2 3/4 4-2 3/4 4-3 3/4 4-3 3/4 4-4 3/4 4-4 3/4 4-9 3/4 4-9 3/4 4-35 3/4 4-35 3/4 5-3 3/4 5-3 3/4 5-6 3/4 5-6 3/4 5-6a
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 265 AND 146 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 (BVPS-1 AND 2)
DOCKET NOS. 50-334 AND 50-412
1.0 INTRODUCTION
By application dated June 1, 2004, as supplemented July 23, 2004 and February 18, 2005, the FirstEnergy Nuclear Operating Company (FENOC, the licensee), requested changes to the Technical Specifications (TSs) for BVPS-1 and 2. The proposed changes would lower the BVPS-2 overpressure protection system (OPPS) enable temperature, allow one inoperable residual heat removal (RHR) loop during surveillance testing, remove the TS list of figures and list of tables from the Index of the BVPS-1 TSs, and make minor changes to achieve consistency between the units and achieve consistency with the Standard TSs (STS) for Westinghouse (W) plants and with some TS Task Force (TSTF) changes.
Specifically, the proposed changes revise various TSs to allow implementation of a lower OPPS enable temperature setpoint on BVPS-2, and allow both units to have one RHR loop inoperable for surveillance testing. The OPPS setpoints are contained in the licensee-controlled, Pressure and Temperature Limits Report [PTLR], which is a section of a the Licensing Requirements Manual [LRM]. Although changes to the PTLR do not require Nuclear Regulatory Commission (NRC) approval, implementation of a lower OPPS enable setpoint requires TS changes for the OPPS-related systems. BVPS-1 and 2's approved PTLR defines the methodologies for the calculation of the pressure and temperature limits and the OPPS enable temperature. The change in the pressure and temperature limits results in a revision of the OPPS enable temperature from 350 EF to 240 EF and changes the applicability requirements from Mode 3 to Mode 4.
2.0 REGULATORY EVALUATION
The OPPS controls reactor coolant system (RCS) pressure at low temperatures so the integrity of the reactor coolant pressure boundary is not compromised by violating the pressure and temperature limits of Title 10 of Code of Federal Regulations (10 CFR), Part 50, Appendix G.
The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only while shutdown; a pressure fluctuation can occur more quickly than an operator can react to relieve the condition.
TSs require control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the PTLR limits. This protection is provided by having a minimum coolant input capability and having adequate pressure relief capacity. Limiting coolant input capability requires having all but one high-pressure injection pump and one charging pump incapable of injection into the RCS and isolating the accumulators. The pressure relief capacity requires either two redundant RCS relief valves or a depressurized RCS and an RCS vent of sufficient size. One RCS relief valve or the open RCS vent is the overpressure protection that acts to terminate an increasing pressure event.
The primary initiator for the licensees proposed changes is the completion of the BVPS-2 Surveillance Capsule W OPPS Analysis. This analysis updates the OPPS setpoints, which are contained in the PTLR, in the LRM. The licensee seeks to lower the BVPS-2 OPPS enable setpoint from 350 °F to 240 °F. The licensee determined the 240 °F setpoint using the NRC-approved methodology in WCAP-14040, Revision 3, "Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves,"
approved on February 27, 2004. Implementation of this setpoint requires TS changes to various plant systems including: (1) safety valve TS Mode applicability, (2) reactor coolant pump (RCP) starting requirement TSs, (3) TS wording for emergency core cooling system (ECCS) subsystems, and (4) deleting the TS note on Mode transitioning for charging pumps, and modification of charging pump inoperability time for pump swapping.
The licensee proposed TS changes to: 1) allow testing of the RHR pumps, 2) delete redundant TS requirements for ECCS Subsystems, 3) make minor changes to the current TSs that are consistent with the STS, NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Revision 2, and TS changes approved by TSTF change travelers TSTF-285, Charging Pump Swap LTOP Allowance, Revision 1, approved May 1999, and TSTF-438, Clarify Exception Notes to be Consistent with the Requirement Being Excepted, Revision 0, approved October 2002.
3.0 TECHNICAL EVALUATION
3.1 BVPS-1 3.1.1 Removal of Lists of Tables and Figures (Note: The changes are discussed in the order listed in the table of Section 2.2 of the June 1, 2004, submittal for both units.)
This change proposes to remove the lists of tables and figures in the Index Section of the TSs because they do not affect plant safety and are not present in the BVPS-2 TSs or the STSs.
This is considered an administrative change and brings BVPS-1 into consistency with BVPS-2 and the STSs, and therefore, their removal is acceptable.
3.1.2 Reactor Coolant System Hot Standby A proposed change to TS 3.4.1.2 consists of modification of the note designated *. It is proposed to make the note consistent with TSTF-438 (Reference 4) and the STSs. The revised note clarifies that the RCPs may be removed from operation (instead of being de-energized) for the same time period of one hour and imposes a limit of once every 8-hour period. In addition, the clarification is added that no operations are permitted which may introduce coolant with a boron concentration less than what is required to meet the shutdown margin. The addition of the 8-hour period is more restrictive than the current note providing assurance that the pumps will be operable when required. A sentence referring to natural circulation under abnormal cooldown conditions is deleted because abnormal conditions are not addressed in the STSs.
The proposed changes and clarifications provide assurance that the pumps will be operable when required, and, therefore, are acceptable.
3.1.3 Reactor Coolant System Shutdown The proposed change to TS 3.4.1.3 consists of a modification of the note designated *** for both units to make this note consistent with TSTF-438 and the STSs. The revised note clarifies that the RCPs may be removed from operation (instead of being de-energized) for the same time period of one hour and imposes a limit of once every 8-hour period. In addition, it is clarified that no operations are permitted which may introduce coolant with boron concentration less than what is required to meet the shutdown margin. The addition of the 8-hour period is more restrictive than the current note providing assurance that the pumps will be operable when required. A sentence referring to natural circulation under abnormal cooldown conditions is deleted because abnormal conditions are not addressed in the STSs. The proposed changes and clarifications provide assurance that the pumps will be operable when required, and, therefore, are acceptable.
3.1.4 Reactor Coolant System Shutdown Note (1) is added to TS 3.4.1.3 to define the allowable time interval for one of the two operable RHR pumps to be taken out of service for pump surveillance. Note (1) states that one RHR may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided that the other RHR loop is operable and in operation. This is only valid for Mode 5. The remaining and operating loop is adequate to cool the core. The 2-hour interval is adequate for the proposed surveillance testing and consistent with the STSs, and, therefore, is acceptable.
3.1.5 Reactor Coolant System Shutdown This change consists of renumbering the notes to TS 3.4.1.3 and includes the addition discussed in 3.1.4 above. This editorial change is acceptable.
3.1.6 ECCS Subsystems - Tavg $ 350 EF This change in BVPS-1 is prompted by the changes described in Section 3.2.8 of this evaluation regarding BVPS-2. For BVPS-1, this change consists of a revision of Note 1 to be consistent with the same note for BVPS-2.
The note provides for transition to TS 3.4.9.3 while it maintains adequate cooling capability for Mode 3. Restrictions of charging pump injection capabilities are in TS 3.5.2, ECCS Subsystems - Tavg $ 350 EF. With this change the number of pumps capable of injecting into the RCS is controlled only by TS 3.5.2. The new note proposed in TS 3.5.2 supports the applicability of TS 3.4.9.3 regarding the maximum of one charging pump capable of RCS injection. At the same time TS 3.5.2 does not allow zero pumps capable of injecting into the RCS. The new note provides sufficient cooling for Mode 3 operation while it satisfies TS 3.4.9.3 applicability requirements, and, therefore, it is acceptable.
3.1.7 ECCS Subsystem - Tavg < 350 EF This change consists of deleting surveillance requirement (SR) 4.5.3.2 from TS 3.5.3. This SR assures that all charging pumps be verified inoperable after entering Mode 4 from Mode 3. The same surveillance is specified in SR 4.4.9.3.1, therefore, SR 4.5.3.2 is redundant and its deletion is acceptable. In addition, deletion of SR 4.5.3.2 provides consistency between the BVPS-1 and 2 TSs and the STSs.
3.1.8 ECCS Subsystem - Tavg < 350 EF This change deletes Note # in TS 3.5.3. Note # specifies that only one charging pump will be operable whenever the temperature of a non-isolated loop with a coolant temperature less than the OPPS enable temperature. This note is redundant because it repeats the requirement of TS 3.4.9.3 that only one charging pump will be operable when the coolant temperature is less than (or equal to) the OPPS enable temperature.
The elimination of this note improves readability of the BVPS-1 TS and makes this TS consistent with the BVPS-2 TS and with the STSs. Because no substantive requirements are affected, the change, therefore, is acceptable.
3.2 BVPS-2 3.2.1 Reactor Coolant System Hot Standby The proposed change consists of the elimination of the note designated # in TS 3.4.1.2 which imposes a restriction in starting a reactor coolant pump in a non-isolated loop in hot standby.
However, the overpressure protection system (OPPS) enable temperature has been revised from 350 EF to 240 EF or from Mode 3 to Mode 4. This eliminated the need for the note.
Corresponding restrictive notes exist for both units for Modes 4 and 5. Because the need for the note was eliminated, the proposed change is acceptable.
Another change to TS 3.4.1.2 consists of modification of the note designated *. It is proposed to make the note consistent with the TSTF-438 (Reference 4) and the STSs. The revised note clarifies that the RCPs may be removed from operation (instead of being de-energized) for the same time period of one hour and imposes a limit of once every 8-hour period. The clarification is added that no operations are permitted which may introduce coolant with boron concentration less than what is required to meet the shutdown margin. The addition of the 8-hour period is more restrictive than the current note providing assurance that the pumps will be operable when required. A sentence referring to natural circulation under abnormal cooldown conditions is deleted because abnormal conditions are not addressed in the TSs. The proposed changes and clarifications provide assurance that the pumps will be operable when required, and, therefore, are acceptable.
3.2.2 Reactor Coolant System Shutdown The proposed change to TS 3.4.1.3 consists of a modification of the note designated *** for both units. It is proposed to make this note consistent with TSTF-438 and the STSs. The revised note clarifies that the RCPs may be removed from operation (instead of being de-energized) for the same time period of one hour and imposes a limit of once every 8-hour period. In addition, it is clarified that no operations are permitted which may introduce coolant with boron concentration less than what is required to meet the shutdown margin. The addition of the 8-hour period is more restrictive than the current note providing assurance that the pumps will be operable when required. A sentence referring to natural circulation under abnormal cooldown conditions is deleted because abnormal conditions are not addressed in the STSs. The proposed changes and clarifications provide assurance that the pumps will be operable when required, and, therefore, are acceptable.
3.2.3 Reactor Coolant System Shutdown The proposed change to TS 3.4.1.3 consists of a modification of the note designated # stating that the restriction of starting the RCP applies only to the first pump. The note specifies that an RCS pump in a non-isolated loop with cold leg temperature at or below the OPPS enable temperature shall not be started unless the secondary side-water temperature of each steam generator (SG) in a non-isolated loop is less than 50 EF above each of the non-isolated cold leg temperatures.
This modification is based on the results of the BVPS-2 surveillance capsule W and is consistent with the BVPS-1 TSs. In addition, analysis demonstrated that RCS-SG fluid mixing occurs, and thermal equilibrium is established within 3 minutes. Therefore, if the second and third pumps are not started before the 3-minute window has passed, there is no need to check the temperatures before starting the second and third pumps. However, the 3-minute window cannot be violated because there are administrative restrains which amount to more than three minutes in restarting one RCS pump immediately after another. The proposed modification is based on the results of BVPS-2 capsule W, provides consistency between the BVPS-1 and 2 TSs, and eliminates the need to read RCS water temperatures before restarting an RCP.
Therefore, the proposed change is acceptable.
3.2.4 Reactor Coolant System Shutdown Note (1) is added to this TS to define the allowable time interval for one of the two operable RHR pumps to be taken out of service for pump surveillance. Note (1) states that one RHR may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided that the other RHR loop is operable and in operation. This is only valid for Mode 5. The remaining and operating loop is adequate to cool the core. The 2-hour interval is adequate for the proposed surveillance testing and in agreement with the STSs, and, therefore, is acceptable.
3.2.5 Reactor Coolant System Shutdown This change consists of renumbering the notes to TS 3.4.1.3 in the order they are encountered and includes the addition discussed in Section 3.2.4 above. This is merely an editorial change and, therefore, is acceptable.
3.2.6 Reactor Coolant System - Safety Valves.
This change consists of adding Mode 4 to the applicability of TS 3.4.3. This is required to implement the change to the OPPS enable temperature from 350 EF (the Mode 3 to Mode 4 boundary) to 240 EF. The enable temperature change was done pursuant to 10 CFR 50.59 through the PTLR; however, the change of the APPLICABILITY required a TS change. This change is essential for the implementation of the 240 EF OPPS enable temperature, and, therefore, is acceptable.
3.2.7 Reactor Coolant System - Overpressure Protection Systems.
This change consists of a modification of Note 1 of TS 3.4.9.3 Reactor Coolant System -
Overpressure Protection Systems. The modification consists of: (1) changing the time allowed for charging pump swapping from 15 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, and (2) deleting the discussion of charging pump injection capability during Mode transitioning.
The proposed pump swap time change is consistent with TSTF-285 (Reference 5) and is consistent with the BVPS-1 version of TS 3.4.9.3 which allows a 1-hour charging pump swapping time, and, therefore, is acceptable.
Restrictions of charging pump injection capabilities are in TS 3.5.2, ECCS Subsystems - Tavg $
350 EF. With this change the number of pumps capable of injecting into the RCS is controlled only by TS 3.5.2. The new note proposed in TS 3.5.2 supports the applicability of TS 3.4.9.3 regarding the maximum of one charging pump capable of RCS injection. At the same time TS 3.5.2 does not allow zero pumps capable of injecting into the RCS. The new note provides sufficient cooling for Mode 3 operation while it satisfies TS 3.4.9.3 applicability requirements, and, therefore, is acceptable.
3.2.8 ECCS Subsystems - Tavg $ 350 EF.
This change refers to modification of Note 1 to TS 3.5.2. This change provides for transition to TS 3.4.9.3 (Mode 4) while it maintains adequate cooling capability for Mode 3, and, therefore, is acceptable. (See also the discussion in Section 3.2.7).
3.2.9 ECCS Subsystem - Tavg < 350 EF This change consists of deleting surveillance requirement (SR) 4.5.3.2 from TS 3.5.3. This SR assures that all charging pumps be verified inoperable after entering Mode 4 from Mode 3. The same surveillance is specified in SR 4.4.9.3.1. Therefore, SR 4.5.3.2 is redundant and its deletion is acceptable. In addition, deletion of SR 4.5.3.2 provides consistency between the BVPS-1 and 2 TSs and the STSs.
3.2.10 ECCS Subsystem - Tavg < 350 EF This change consists of deleting the Note designated ** in SR 4.5.3.2 which itself was deleted as described in Section 3.2.9 above. This note described one of the ways charging pumps can be demonstrated incapable for RCS injection. Such methods have been added to the TS Bases consistent with the practice employed in the STSs. Deletion of this note does not change the contents of the TSs, and is consistent with the STSs, and, therefore, is acceptable.
Note: The correction submitted in the July 23, 2004, supplement (Reference 2), refers to an ACTION statement added to TS 3.5.3 to exclude the application of TS 3.0.4.b to the ECCS centrifugal charging pumps. TS 3.0.4.b states that, After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the OPERATIONAL MODE or other specified condition in the APPLICABILITY, and establishment of risk management actions, if appropriate; exceptions to this specification are stated in the individual specifications. This modification of TS 3.5.3 was submitted March 22, 2004, by a separate license amendment request and was approved November 4, 2004, as BVPS-1 and 2 Amendments Nos. 263 and 144, and is not part of this review. However, the provision of TS 3.0.4.b does not apply to OPPS, and, therefore, was not evaluated under this amendment request.
3.3 Summary The NRC staff reviewed the information submitted by FENOC and the associated request for TS changes necessitated by the change of the OPPS enable temperature from 350 EF to 240 EF. This relocated the enable temperature from Mode 3 to Mode 4. (This submittal included only the TS changes and not the calculation of the actual enable temperature.) The NRC staff found that the proposed changes fulfilled one or more of the following conditions:
- 1) were necessary because of the change in the OPPS enable temperature, 2) brought the BVPS-1 and 2 TSs into consistency with the STSs, and 3) eliminated redundancy. The proposed changes did not change the intent or the requirements of the TSs, and, therefore, the NRC staff finds them acceptable.
4.0 EXIGENT CIRCUMSTANCES
The licensee requested exigent approval of the license amendments in its supplemental application dated February 18, 2005 (Reference 3). A Notice of Consideration of Issuance of Amendment to Facility Operating License, Proposed No Significant Hazards Consideration, and Opportunity for Hearing, was published in the Federal Register on February 25, 2005 (70 FR 9391). In accordance with the provisions of 10 CFR 50.91(a)(6), comments were requested within 14 days after the date of publication and hearing requests within 60 days after the date of publication.
The February 18, 2005, supplement provided a description of the exigent circumstances related to the requested license amendments. The licensee stated that on February 17, 2005, the requirements of 10 CFR 50.91(a)(2) had not been satisfied, in that Notice for public comment on the above referenced license amendment request had not been published in the Federal Register. The licensee further determined that there would be insufficient time to provide for the normal 30-day notice prior to the approval and implementation of the amendment without requiring plant shutdown. The licensee stated that it complied with all applicable requirements for completeness and timeliness in submitting the above license amendment application.
Approval had been requested by February 15, 2005, to support revision of the existing BVPS-2 pressure and temperature limit curves prior to their expiration in mid-March 2005. In light of the above situation, the licensee requested that the NRC consider these circumstances exigent and requested that further processing of the license amendment request be completed under the provisions of 10 CFR 50.91(a)(6).
The failure to publish the Notice for public comment in the Federal Register in a timely manner could not have been foreseen by the licensee.
The NRC staff has evaluated the licensees explanation of the exigent circumstances and has determined that a valid need exists for issuance of the requested amendments in accordance with the exigent provisions of 10 CFR 50.91(a)(6).
5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION The regulations at 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards considerations, if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
These amendments have been evaluated against the standards in 10 CFR 50.92 as discussed below:
1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
No. The modification to the Applicability of TS 3.4.3, Safety Valves, provides alignment with the Applicability of TS 3.4.9.3, Overpressure Protection Systems, such that the TSs assure that overpressure protection is specified over all operational modes.
The modification and deletion of Notes associated with the reactor coolant system (RCS) injection capability of the charging pumps during Mode transitioning results in a single Note that controls the charging pump restrictions and is consistent with the standard technical specifications (STS). As a result the charging pump RCS injection capabilities during Mode transitioning restrictions are either not changed or made more restrictive by the proposed changes.
The BVPS-2 OPPS analysis documents that the TS imposed primary to secondary temperature restriction on starting each of the RCPs [reactor coolant pumps] is necessary for only the first RCP because thermal equilibrium of the reactor coolant system (RCS) is achieved shortly after the first pump is started. As a result an RCS heat injection event continues to be precluded.
The change from 15 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for charging pump swapping operations will not result in a significant increase in the probability of a low temperature overpressure event because the overall time allowed for pump swapping is short. Although the increase in time permits two charging pumps being capable of RCS injection during the Applicability of the OPPS TS, the hour is very short and permitted only for pump swapping operations. These operations are deliberate actions that are well controlled and accomplished in the shortest time possible.
The addition of a Note associated with the testing of an RHR pump will not result in a significant increase in the probability of an accident during Mode 5 because the RHR pumps are not an accident initiator and will not result in a significant increase in the consequences of a Mode 5 accident because the required cooling capability will be provided by the RHR train that is required to be in operation during the surveillance test of the inoperable RHR pump.
The additional restrictions imposed on removing the reactor coolant pumps and residual heat removal pumps from operation during Modes 4 and 5 further restrict removing these pumps from operation, thereby providing assurance the pumps will be operable when required.
The other changes, i.e., elimination of duplicated TS requirements, renumbering and reordering of various Notes and the deletion of the [BVPS-1] List of Figures and Tables, are made to improve the consistency between the BVPS-1 and 2 TSs and with the STS and have no affect on plant operations.
None of the proposed changes are initiators of any accident previously evaluated.
Therefore, the probability of an accident previously evaluated is not significantly increased. The consequences of an accident are also not affected by the proposed changes because none of the proposed changes will result in a change in the effluent that may be released offsite, the release duration or the release path.
Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
2.
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
No. None of the proposed changes involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the operation of plant equipment. Entering into the applicability of a TS, or utilization of the applicable Notes, will not introduce new failure modes or effects and will not, in the absence of other unrelated failures, lead to an accident whose consequences exceed the consequences of accidents previously evaluated.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Does the proposed change involve a significant reduction in a margin of safety?
No. None of the proposed changes impact the existing margin of safety. The proposed changes assure that the affected components and systems are operable or incapable of RCS injection when required, thereby maintaining the existing margin of safety.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on this review, the Commission has made a final determination that these amendments involve no significant hazards considerations.
6.0 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.
7.0 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 made a final finding that the amendments involve no significant hazards consideration. 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.
8.0 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.
9.0 REFERENCES
1.
L. William Pearce, FirstEnergy Nuclear Operating Company, FENOC, letter to NRC, Beaver Valley Power Station, Units 1 and 2, License Amendment Request Nos. 326 and 177, dated June 1, 2004.
2.
L. William Pearce, FENOC, letter to NRC, Beaver Valley Power Station, Unit 1, Supplement to License Amendment Request Nos. 321 and 326, dated July 23, 2004.
3.
L. William Pearce, FENOC, letter to NRC, Beaver Valley Power Station, Units 1 and 2, Exigent License Amendment Request Nos. 326 and 177, dated February 18, 2005.
4.
TSTF-438, Clarify Exception Notes to be Consistent with the Requirement Being Excepted, Revision 0, approved October, 2002.
5.
TSTF-285, Charging Pump SWAP LTOP Allowance, Revision 1, approved May 1999.
Principal Contributors: L. Lois V. Hall Date: March 11, 2005