ML20059E377
| ML20059E377 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/30/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20059E369 | List: |
| References | |
| GL-90-06, GL-90-6, NUDOCS 9009100156 | |
| Download: ML20059E377 (4) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMFNDMENT NO. 32 TO FACILITY OPERATING LICENSE NO. NPF-73
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DUQUESNE LIGHT COMPANY OH10 EDIS0N COMPANY
,THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLED0 EDISON COMPANY i
i BEAVER VALLEY POWER STATION. UNIT N0. 2 DOCKET NO. 50-412 j
1.0 INTRODUCTION
By letter dated June 11, 1990, Duquesne Light Company proposed a revision to the surveillance requirements applicable to the Overpressure Protection System attrecifiedintheBeaverValleyPowerStation, Unit 2(BVPS-2) Technical Specifications (TSs).Section3/44.9. The pro nsed revision would delete
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paragraph 4.4.9.3.1.d of that section which requires stroking each operable 1
power-operated relief valve (PORV) each time the plant enters Mo d 5 unless j
stroke-testing was performed previously on the PORY '/ithin 3 months.
1 With respect to other surveillance requirements applicable to the PORVs TS
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Section.3/4 4.11 requires that the FORVs are to be demonstrated operable at i
least once per 18 months by opereting the valve (s) through one complete cycle of full travel.
The specification, however, is not specific as to the 1
conditions under which the demonstration is to be conducted, On June P0,1990, the Comission issued Generic Letter (GL) 90-06 which represents the technical resolution of Generic Issue 70, " Power-0 pere wd Relief Yalve and Block Valve Reliability", and Generic Issue 94 "Nditional i
Low Tem)erature Overpressure Protection for Light Water Reactor r.
Among other t1ings, GL 90-06 clarifies the staff's position on the conditions under which surveillance-testing of the PORVs is to be done. All pressurized water i
reactor licensees and applicants are to respond to GL 90-06 by Dicen6er 17, 1990. While this safety Evaluation partially resolves one of the issues c
embodied in GL 90-06, it is not intended to address totally the specific issues to which the responses to GL 90-06 Lst be directed, j
2.0 DISCUSS 10H AND EVALUATION The BVPS-2 TSs contain three specific requirements for the surveillance testing (inadditiontovariousotherchanneltestsandcalibrations)ofthe 3
PORVs as follows:
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o 1.
Paragraph 4.4.9.3.1.d states that "Each PORV shall be demonstrated OPERABLE by stroking the operable PORVs each time the plant enters:
MODE 5, unless tested within the preceeding 3 months",
e 2.
. Paragraph 4.4.11.1 b states that "In addition to the requirements of=
Specification 4.0.5, each PORV shall be demonstrated OPERABLE a' L
least once per 18 months by operating the valve through one complete cycle of full travel".
3.
Paragraph 4.0.5-spe # 1es, in part, that the inservice testing requirements of Section XI of the ASME Code Class 1, 2, and 3 pumps-l and~ valves shall be applicable and shall be.in addition to other specified surveillance requirements.
The BVPS-2 Inservice Testing (IST) Program provides for the testing of the P N Ys it least quarterly but includes a cold shutdown justification to permit L
Ja % ng a scheduled test h.itil the unit is in cold shutdown so-as to avoid l
m d 'ng the PORVs while the plant is at power.
The IST test includes vah e-stroke timing in addition to cycling the PORVs.
The Standard Technical
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Specifications (STS) for Westinghouse Pressurized Water Reactors, NUREG-0452 (Rev. 4), only provides.for the testing of PORVs'in accordance with the l
requirements of inservice testing. The STS require an operational test of the PORV actuation chanael within 31 days prior to entering a condition in which l
the PORV is required to be operable, but that requirement specifically excludes operation.of the PORV.
GL 90-06 requested licensees to include PORVs and PORV block valves in an:
operational quality assurance. program within the scope of the IST programpand k
to adopt certain technical specification changes in accordance with staff positions. With respect to the inclusion of,the PORV into the IST= program, the GL specifically.noted that stroke-testing of PORVs should only.be r
performed during Mode 3 or Mode 4 and, more generally, such stroke-testing
.should only be performed when plant conditions ~are such that low-temperature overpressure protection is not required.
Additionally, the staff-endorsed technical specifications included with 90-06 would require operation of the PORV through one complete cycle of full travel during Modes 3 or 4.at=least once per 18 months.
Thus, the requirement'of. Paragraph 4.4.9.3.1.d of the BVPS-2 is not consistent with the staff position that testing of PORVs should not be performed when the plant is in a condition where'the PORVs are being relied'upon for-1 low-temperature overpressure protection.
The staff's position is based upon consideration of the unavailability of the PORVs for the period of time
' required to perform the testing while the plant is in a condition where a low-temperature overpressure transient is most likely to occur.
The staff, in fact, co'ncluded that while. low temperature overpressure protection is required
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'in all shutdown modes,.the'most vulnerable period of time is in Mode 5 with the reactor coolant temperature less than 200 F (NUREG-1326, Regulatory Analysis for the Resolution of Generic Issue 94, " Additional Low-Temperature
- 0verpressure Protection for Light-Water Reactors").
Low temperature overpressure protection is required at BVPS-2 4 :'ever the temperature of at lust one non-isolated reactor coolant syram ccM leg O 350'F or less.
Thus, low temperature overpressure protection u ? equred whenever the plant is in operational modes 4 or 5, and in Mwe 6 'f De head
.is on the vessel.
To meet the staff position stated in GL 90 00, 5Ni atrok-tesing at BVPS-2 should be done only in Mode 3.
Based on the above, we find that the requirement of.TS Paragraph 4.4.0.3.1.d is not consistent with the ctated staff position because the subject L
surveillance requirement would require PORV stroke-testing at a time when plant conditions have been established which require low temperature overpressure protection. Other surveillance requirements currently incorporated in the BVPS-2 TSs, namely, the requirements of Paragraphs 4.4.11.1 b (if performed while in Mode 3) and 4.0.5 would meet the staff L
position with regard to surveillance testing requiring stroking of the PORVs.
Based on the above, we agree with the licensee's assertion that the
. requirement of TS Paragraph 4.4.9.3.1 d is redundant; we find, further, that adequate stroke-testing of the PORVs is required by Paragraphs 4.4.11.1 b and 4.0.5.
The deletion of Paragraph 4.4.9.3.1 d would-eliminate a requirement to perform testing of the PORVs while:the reactor coolant system is most vulnerable to_an overpressure transient requiring mitigation through the use of.the.PORVs.
Therefore, the~ deletion of TS Paragraph 4.4.9.3.1 d is acceptable.. It is to be noted, however, that this Safety Evaluation is limited solely to the issue of the deletion of the subject paragraph..
Duquesne Light Company must still respond to the staff on the issues covered by GL 90-06.
The staff will review that response at a later date.
ENVIRONMENTAL CONSIDERATION This amendment changes surveillance requirements.
We have determined that ij the amendment involves no significant increase in the amounts, and no l
significant change in the types, of any effluents =that may be released j
offsite, and that there is no significant increase in individual-or cumulative L
occupational radiation exposure.
The staff has previously issued a proposed l
finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding.
Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 l
CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environental impact statement L
or environmental assessment need be prepared in connection with the issuance of the amendment.
CONCLUSION ~
We hav,e 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, and (2) such l
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activities will be conducted in compliance with the Comission's regulations,'nd (3) the issuance of the amendment will not'be-inimical-to the a
Mormion defense and. security or to the health and safety of the public.
Dated: ' August 30.-1990 Principal Contributor:
. Albert W. De Agazio g
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