ML20044A369

Proposed Tech Specs,Consisting of Tech Spec Change Request 44,changing Stroke Time to 60 for Inside Containment Letdown Isolation Valves

ML20044A369
Person / Time
Site:	Beaver Valley
Issue date:	06/21/1990
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20044A367	List: ML20044A366 ML20044A368 ML20044A369
References
NUDOCS 9006280402
Download: ML20044A369 (8)

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ATTACHMENT A 79

-Revise tha' Beaver Valley Unit No. 2 Technical Specifications as ifollows: .,

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CONTAllO Uli PENETRATIONS MEA IDENTIFICATION / DESCRIPTION A L TE EC) VL TE SEC)

) 515-84 N/A (3)(2) 2 SIS-9RIY8698 N/A' ty jection.

19 Seal Water from (A) 2CHS-MOV378 < 60 (A) 2CHS-MOV381 -< 60 Reactor Coolant Pump 2CHS-473 N/A 20 Safety Injection 2 SIS-42 N/A (1) 2S15-41 N/A Accumulator Makeup 2 SIS-RV130 N/A 7% 21 Chill & Service Wtr _(B) 25WS-MOV155-2 < 60 (B) 25WS-MOV155-1 < 60 Dt from Cont. Air 25WS-RV155 N/A Recirc Cooling Colls f

@$ 22 SPARE 23 SPARE 24 Residual Heat-Removal 2RHS-107 N/A 2RHS-15 N/A to Refueling Water Tank 2RHS-RV100 N/A 25 Chill & Service Wtr (B) 25WS-MDV154-2 < 60 (B) 25WS-MOV154-1 < 60 from Cont. Air Recirc 25WS-RV154 N/A Cooling coils '

27 . hi & i r (B) 25WS-MDV152-2 <-60 -(B) ~25WS-MOV152-1 .< 60

.2SWS-RV152 N/A-Cooling C'ils o

28 Reactor Coolant Letdown (A) 2CHS-A0V200A -le- < so (A) 2CHS-A0V204 < 60 (A) 2CHS-A0V2000 -le- < 6 o (A) 2CHS-A0V200C -le- < g o

-(1). .2CHS-HCV142- N/A' 2CHS-RV203 N/A

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ATTACEMENT B Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification Change No. 44 REVISION OF TABLE 3.6-1 LETDOWN ISOLATION VALVE RESPONSE TIME x .. -

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-. - . . . y A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment replaces the 10 second stroke time specified for Table 3.6-1, penetration 28, inside containment isolation valves (2CHS-AOV200A,B and C) with a stroke time of less than 60 seconds. This reflects our commitment to submit a request for Technical Specification Change set forth in our letter dated June 7, 1990 for a temporary waiver of compliance.

B. BACKGROUND The inside containment isolation valves were stroked during performance of our quarterly slave relay testing. During this test, it was found that the RCS containment isolation valve stroke times were greater than the 10 seconds currently specified in Table 3.6-1. This had not been found in previous tests since this test does not normally stroke time these valves. These valves are normally stroke time tested using the benchboard control switches. When tested using the benchboard control switches, these valves consistently stroked in less than 10 seconds. The difference in stroke times between the two tests results from the difference in the circuit configurations.

Since the valve stroke times were longer than the 10 second limit, the valves were declared inoperable and the penetration was isolated in accordance with Action Statement 3.6.3.1.b. The plant then used the excess letdown flowpath; however, operating in this manner has previously resulted in RCS chemistry control problems that could lead to plant shutdown in accordance with specification 3.4.7. Therefore, a temporary waiver of compliance was initiated to allow operation using the normal letdown flowpath based on isolation valve stroke times of less than 60 seconds until a permanent technical specification change could be implemented.

C. JUSTIFICATION The inside containment isolation valve stroke time for the normal RCS letdown piping penetration is 10 seconds as specified in Table 3.6-1 for penetration 28. The outside containment isolation valve stroke time specified is 60 seconds. The 10 second stroke time was intended to assure the inside valves would close before the outside valve to prevent the penetration relief valve from lifting. This valve closing sequence is intended as a prudent operating characteristic of the system to prevent unnecessary relief valve opening and flashing in the regenerative heat exchangers. While not a safety concern, it is an operating concern. This relief valve is located in containment and discharges to the prec;urizer relief tank; therefore, no release to the environment can occur. There is no safety or radiological

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Proposed Technical Spscification. Change No. 44

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-concern forL the difference. in stroke times between the inside containment isolation valves- and the outside containment

-isolation. valve. Therefore, the inside containment isolation Lvalve stroke times have been changed from 10 seconds to less than 601 seconds to be consistent .with the outside containment

. isolation 1 valve stroke time. ,

, . , - D. SAFETY ANALYSIS

'UFSAR Section 6.2.4.2 specifies a maximum closure time of 60 seconds- or less for. any containment . isolation valve. In addition, the function of the relief valve is described, such that, water . trapped between isolation barriers may expand during a DBA due to thermal effects, creating pressures greater:than the piping design- limit. Therefore, overpressure protection is provided- by a relief: valve located between the isolation valves with- a setpoint belowLthe piping design pressure. These valves i . are designed to reseat when the overpressure conditions subside.

The relief valve is located in containment and discharges to the pressurizer relief tank, therefore, there would be no release to the environment if the relief valve were to lift.- The proposed technical specification' change- is consistent with the UFSAR philosophy regarding containment isolation valvo maximum' stroke time and the intended operation of the relief valve. Therefore, the proposed change is considered tc be safe 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 proceduree in paragraph 50.91, that a proposed amendment to an operating license for'a facility -licensed under paragraph 5'.21(b) 0 or paragraph 50.22 or for a cesting facility involves'no significant hazards consideration, 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; or (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.

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Proposod-Tachnical Sp*cification Changs No. 44 Page'3-

, , The 'following evaluation is provided_ for the no significant g hazards consideration standards.

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1. Does the change involve a significant increase in the probability or' consequences of an_ accident previously

' evaluated?

0P Changing the .inside containment' isolation valve stroke time H for the: normal RCS letdown piping . penetration from 10 seconds to less than 60 seconds is consistent with the stroke time specified for the outside containment isolation o; , valve for this penetration. Since a relief valve is located between the inside and- outside isolation valves and would a discharge to .the pressurizer relief-tank, there would beino

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release to the environment if it were to lift.

6 There is no safety concern for this change since .the penetration would be isolated within the time specified in the UFSAR. Therefore, the proposed changes do'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?

A stroke time of less than 60 seconds for the inside containment isolation valves satisfies the UFSAR criteria for penetration isolation during a DBA. Changing the stroke time' will not reduce - the reliability of the containment isolation system. The function of.the isolation valves:and the relief valve -for this' penetration tare not being changed. Therefore, the- proposed changes will not create the possibility of a new or different' kind of accident from-any accident-previously evaluated.

3. Does the change involve a significant reduction in-a' margin of safety?

Performance of the isolation function for this penetration is consistent with the UFSAR 60 second isolation criteria.

Because 'these valves will close within 60 seconds, the safety analysis assumptions will not 'be affected'in any-way. Therefore, the proposed changes will not involve a significant reduction in a margin of safety.

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

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PropossdfTschnical Spscification Changs No. 44

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G. ENVIRONMENTAL EVALUATION The- proposed- changes have. been evaluated and it has been determined. that the changes do not. involve (i) a significant hazards.. consideration, (ii) a significant change in the types.or significant- increase in the amounts ofiany effluents that may be.

released; offsite, or (iii) a'significant increase in individual or cumulative occupational radiation-exposure. Accordingly,-the proposed changes meet the eligibility criterion for categorical excl'usion set forth in 10 CFR 51.22 (c) (9) . Therefore,. pursuant; to 10 CFR 51.22 (b), an environmental assessment of the proposed changes is not required.

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, , ATTACHMENT C-

Beaver LValley Power. Station, Unit No. 2' t, '

Proposed Technical Specification Change No. 44 I' ~

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