ML20043G814

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Proposed Tech Specs Consisting of Proposed Operating License Change Request 41 to Delete Surveillance Requirement 4.4.9.3.1.d
ML20043G814
Person / Time
Site: Beaver Valley
Issue date: 06/11/1990
From:
DUQUESNE LIGHT CO.
To:
Shared Package
ML20043G801 List:
References
NUDOCS 9006210159
Download: ML20043G814 (6)
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ATTACHMENT A 1 ge' 4~~

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-Revise the technical Specifications as follows: J

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,, we REACTOR C00lANi SYSTEM KURVEILLANCE REQUIREMENT 1(continuadi c.- Verifying the PORV isolation valve is open at least once per i

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> wra.n the PORV is being used for overpressure protection.  !

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d. Stroking the operable PORV(s) each time the plant enters MODE 5,
j. Q ,unless tested within the preceding 3 months. l 4.4.9.3.2 The > 3.14 square inch RCS vent (s) shall be verified to be open.at  !

least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

  • when the vent (s) is being used for overpressure. l p ' protection, '

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  • Except when the vent pathway is provided with a valve which is locked, or provided with remote position indication, sealed, or otherwise secured in the open position, then verify'these valves open at least once per 7 days.

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BEAVER VALLEY - UNIT 2 3/4 4-36 (froposed Word

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ATTACHMENT B 1 i

Beaver Valley Power station, Unit No. 2

< Proposed Technical Specification Change _No. 41 Revision of Technical Specification 3.4.9.3 ,

OVERPRESSURE PROTECTION SYSTEMS '

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A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would delete surveillance requirement {

4.4.9.3.1.d.. This surveillance requires the Power Operated Relief-Valves (PORV's) associated with the Cold overpressure Protection 1

-System (COPPS) to be stroke tested every time the plant enters "

Mode 5 if not tested within the preceding three months.  !

i B. BACKGROUND The Beaver Valley Unit 2 COPPS consists of two independent trains of protection. Each train monitors Reactor Coolant Systems (RCS) i temperature and pressure conditions. An auctioneered temperature-is connected to an allowable pressure (as described in Figure 3.4-4 of -the Technical Specifications) and whenever the measured pressure is greater than or equal to the allowable pressure an- ,

3 actuation signal is transmitted to_-mitigate the pressure transient. The COPPS uses two of the three Pressurizer PORV's to-provide the required system relief. .The system is manually armed-and required to be. operable whenever tt 'S is less than or equal  !

The PORV's for Unit 2 use a_ solenoid-operated-pilot valve for valve- operation. These. valves require a minimum system pressure '

(approximately 60 psig or greater) to : operate. These PORV's are ,

not designed.to be maintained.in the open position and, therefore, '

cannot-be utilized to provide the required 3.14 square inch vent.

C. JUSTIFICATION i

Deletion of this surveillance requirement would be consistent-with the Standard Technical Specifications wording. The PORV operability surveillance requirement for COPPS in the Standard  ;

Technical Specifications specifically excludes valve operation.

This- is acceptable since the PORV's are stroke tested per other requirements. These valves are required to be stroke tested every-

' 18 - months per specification 3.4.11. In addition, these valves are stroke tested every plant cold shutdown, unless tested within the- '

preceding. 3 months, per the Beaver Valley Unit 2 ASME Section XI ,

testing program.

-The current wording of surveillance requirement 4.4.9.3.1.d'is potentially confusing to the plant operators. The present wording requires each operable PORV to be stroke tested when the plant enters Mode 5, it does not define how soon after entering Mode 5 this surveillance should be completed. This wording also contributes to scheduling conflicts since there are three other PORV stroke testing requirements for Mode 5. I

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, Pr:por d Tcchnical specific 2tien Chtngo N3. 41 Page 2 Therefore, deletion of surveillance requirement 4.4.9.3.1.d will be consistent with the Standard Technical Specifications wording, remove redundant stroke testing requirements, provide added flexibility for scheduling of PORV stroke testing, and remove potentially confusing wording from the Beaver Valley Unit 2 Technical Specifications.

D. SAFETY ANALYSIS The operability of the PORV's for COPPS ensures that the RCS will be protected from pressure transients which could exceed the limits of Appendix G of 10 CFR Part 50. Either PORV has the capacity to protect the RCS from overpressurization for relievinfgn any des basis pressure transients. Operability requirements [

for both PORV's ensures that these valves will be available to '

provide protection against any notential overpressure transient assuming any single failure within the COPPS. Periodic stroke testing of these valves verifies thstr operability. The proposed change will not eliminate stroke testing requirements of the PORV's. With the proposed change sufficient surveillance requirements will continue to exist to ensure the operability of these valves. Therefore, this change vill not effect the design capability or availability of the COPPS as assumed in the analysis for overpressure protection and will not reduce the safety of the plant.

E. NO SIGNIFICANT HAZARDS EVALUATION The no significant hazard considerations involved with the proposed amendment have been evaluated, focusing on the three standards set forth in 10 CFR 50.92(c) as quoted below:

The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment to an operating license for a facility licensed. under ,

paragraph 50.21(b) or paragraph 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would nots (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a .tew or different kind of accident from any accident previously evaluated; or l (3) Involve a significant reduction in a margin of safety. i e

The following evaluation is provided for the no significant

. hazards consideration standards.

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, Proposed Tochnical Specificatien Chtngi No. 41 Page 3

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The operability of the PORV's for COPPS will be maintained to protect the RCS from overpressurization for any design basis pressure transients which could exceed the limits of Appendix G of 10 CFR Part 50. .The PORV's will still be demonstrated to be operable by periodic stroke testing, which is required by Technical Specification surveillance requirement 4.4.11 and ASME XI.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

The design and function of the PORV's will not be altered by this proposed enange. The PORV's will still provide overpressure protection for any design basis . pressure i transients which could exceed the limits of Appendix G of 10 CFR Part 50. The proposed change will not eliminate the stroke testing requirements of the PORV's which assures valve operability.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any i accident previously evaluated. I

3. Does the change involve a significant reduction in a margin of sittety?

Sefticient surveillance requirements will continue to exist i to ensure the operability of the PORV's. This change will not affect the design capability or availability of the COPPS as assumed in the analysis for overpressure protection.  !

Therefore, the proposed change does not involve -a significant reduction in a margin of safety. .

F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the considerations expressed above, it is concluded that the activities associated with this license amendment request satisfies the- no significant hazards consideration standards of 10 CFR 50.92(c) and, accordingly, a no significant hazards consideration finding is justified.

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PropO d TOchnic31 Specific;ticn Ch0ng3 N3. 41 )

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J G. ENVIRONMENTAL EVALUATION l l

The proposed changes have been evaluated and it has been determined that the changes do not involve (1) a significant i hazards consideration, (ii) a.significant change in the types or l significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupat'onal radiation exposure. Accordingly, the -

proposed changes meet the eligibility criterion for categorical j exclusion set forth in 10 CFR 51.22 (c) (9). Therefore, pursuant  ;

to 10 CFR 51.22 (b), an environmental assessment of the proposed l changes is not required.

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