Text

Proposed Tech Specs 3.4.9.3 & 3.4.11,incorporating PORV Requirements in Accordance W/Gl 90-06 as Implemented in NUREG-1431,Improved Sts,W/Some Exceptions & Mods to Reflect Plant Specific Design Features
	ML20065M339
Person / Time
Site:	Beaver Valley
Issue date:	04/19/1994
From:	; DUQUESNE LIGHT CO.
To:	;
Shared Package
ML20065M338	List: ML20065M336; ML20065M339;
References
	RTR-NUREG-1431 GL-90-06, GL-90-6, NUDOCS 9404250297
	Download: ML20065M339 (100)
	v • d • e

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l ATTACHMENT A-1 Beaver Valley Power Station, Unit No. 1 Proposed Technical Specification change No. 184 I MARKED-UP PAGES The following is a list of the affected pages:

Affected Pages: 3/4 1-11 3/4 3-50 3/4 3-52 3/4 4-27a 3/4 4-27b 3/4 4-29 3/4 5-2 B 3/4 4-10 B 3/4 4-11 1

I e

O l

9404250297 940419 4 PDR ADOCK 0500 P

DPR-66 REACTIVITY CONTROL SYSTEMS CHARGING PUMP - SHUTDOWN of Isasf LIMITING [CONDITIONFOROPERATION l 3.1.2.3 E gInechargingpumdOin the boron injection flow path required by Specification 3.1.2.1 or gow gead gafety /njection gump (with an I open reactor coolant system vent of greater than or equal to 3.14 ;

square inches) shall be OPERABLE and capable of being powered from l an OPERABLE bus. 1 APPLICABILITY: MODES 5 and 6. l l

ACTION: '

abovt With none of the charging pumps OPERABLE, suspend all operations l l involving CORE ALTERATIONS or positive reactivity changes until one charging pump or gow gead gafety /njection pump is restored to l OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.1.2.3.1 The above required charging pump shall be demonstrated OPERABLE by verifying, on recirculation flow, that the pump develops a discharge pressure greater than or equal to 2402 psig when tested pursuant to specification 4 0.g. g g .j./g .y, y, q y 4.1.2.3.2 All charging pumps, except the above required chargingh pump, shall be demonstrated inoperable

at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the control switches are placed in the)

PULL-TO-LOCK position and tagged. >

4.1.2.3./.? When the gow gead gafety gnjection pump is used in lieu of. a charging pump, the gow fead gafety /njection pump shall be demonstrated OPERABLE by:

a. Verification of an operable RWST pursuant to 4.1.2.7,

b. Verification of an operable gow gead gafety /njection gump l pursuant to Specification 4.5.2.b.2,

c. Verification of an operable gow gead gafety gnjection flow l path from the RWST to the Reactor Coolant System once per shift, and

d. Verifiggtio hat the vent . M ^"^= -

ham;i. M CCCC o rda nc e, w @ 4 $ 9.W. h' '- Ot Once-per 12-

_. _ _ Dele Te

An inoperaole pump may be energized for testing provided the discharge of the pump has been isolated from the RCS by a closed isolation valve with power removed from the valve operator, or y a manual isolation valve locked in the clos ed Dosition.

D)

__ k} r A t.J n Cka toUa nkn OPERR8LEAlla SoecKeatok 2N.9.3.

Except when the vendr phth is provided with a Valve which f35 locked or provided with remote position indication, or sealed, l or otherwise secured in the open position, then verify these/

gj alves open at least once per 7 days. ~

1 BEAVER VALLEY - UNIT 1 3/4 1-11 Amendment No. ,

PRO posed 1

DPR-66 INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.8 The accident monitoring instrumentation channels shown in Table 3.3.11 shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

a. With the number of OPERABLE ' accident monitoring instrumentation channels less than the Total Number of Channels shown in Table 3.3.11, either restore the inoperable channel (s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours c.xcept rm. *wm onotr , a

.,w4mw

..,wm 4 ,,,,.*ma 4. ..,,,,,-a--,,- .4w

([o//cw Specif5 cation 33.11.[edd MtN[,[. NA/.5 [hf[$ $b l

b. With the number of OPERABLE accident monitoring instrumentation channels less than the MINIMUM CHANNELS OPERABLE requirements of Table 3.3.ill, either restore the inoperable channel (s) to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or Specohbafyhr L HOT be in at least SHUTDOWN within the next 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months sy(h//vu/ l 4, // 4% de ferm,&g acnom Sa %m yd

c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.8 Each accident monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-7.

BEAVER VALLEY - UNIT 1 3/4 3-50 Amendment No.

PR0f'osED

o .-

=o J3 e

TABLE 4.3-7

ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REOUIREMENTS CHANNEL CilANNEL CHECK CALIBRATION

1. Pressurizer Water Level M R

2. Auxiliary Feedwater Flow Rate S/U (1) R

3. Reactor Coolant Systein Subcooling Margin .

M R

4. PORV Acoustical Detector Position Indicator M R

5. PORV Limit Switch Position Indicator M R

6. PORV Block Valve Limit Switch Position Indicator M R

7. Safety Valve Acoustical Detector Position Indicator M R

8. Safety Valve Temperature Detector Position Indicator M R DyeYed 1 3 FvdV Centrcl Presserc Channcls (PT-RC 444, 445) ". R

10. Containment Sump Wide-Range Water Level M R

11. Containment Wide-Range Pressure N/A R

12. In-Core Thermocouples (Core-Exit Thermocouples) M R

13. Reactor Vessel Level Indicating System M R (1) Channel check to be performed in conjunction with Surveillance Requirement 4.7.1.2.c following an extended plant outage.

BEAVER VALLEY - UNIT 1 3 3-52 Amendment No.

Onp/4s & cJo d ;y )

DPR-66 REACTOR COOLANT SYSTEM OVERPRESSURE PROTECTION SYSTEMS LIMITING CONDITION FOR OPERATION ffV M /

.4.9.3 At least one of the following overpressure protectixn s' tems shall be OPERABLE: ,/

Two

/

power operated relief valves (PORVs) with a nomina'l trip setpoint of less than or equal to 432 psig, or ,/

b. reactor coolant system vent of greater than'or equal to

3. 4 square inches.

APPLICABILITY: When the temperature of one' or more of the non-isolated RC cold legs is less than or'. equal to an enable temperature of 32 *F.

p/

/

ACTION: g/ ,

/

a. With one PORV operable, e.ither restore the inoperable PORV to OPERABLE sta s within 7 days or depressurize and vent

/

the RCS through 3.1,.4 square inch vent (s) within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; PORVs have maintain been r the RCS in a vented condition until both ored to OPERABLE status. Refer to Technical Specifica ion 3.4.1.6 for further limitations.

b. With both PORyls inoper ble, depressurize and vent the RCs through a 3.A4 square inch ent(s) . within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; maintain the RCS ip' a vented con $ tion until both PORVs have been restored td OPERABLE status.

/ \

c.

The p/rovisions of specification 3. .4 are not applicable.

/

SURVEILLANCE REQUIREMENT 4 4.9.3.1 Each PORV shall be demonstrated OPERABLE B BEAVER VALLEY - UNIT 1 3/4 4-27a Amendment No.

fA0 &$fb

-DPR-66 REACTQP COOLANT.. SYSTEM g gggg SURVEILLANCE REQUIREMENTS (Continued) /

V Performance of . a CHANNEL FUNCTIONAL TEST on the PC actuation. channel,-but excluding valve' operation, withi 31 days prior to entering a condition in which the P .V is quired . OPERABLE. and at least once per 31 days th eafter wh the PORV is required' OPERABLE.

b. Perfo nce of. a CHANNEL CALIBRATION on the V actuation channel t least once per is months. ;

c. Verifying a PORV '/

isolation open at least once per 72 ho valve is ,d for overpressure' protection. when the PORV is beinguse '

/ l i

d. Stroking the o able PORV(s)

/

e,ach time the plant enters

\

Mode 5, unless test d within the preceding three months. ./,

4.4.9.3.2 The it 3.14 square i h RCS vent (s) shall be verified to be open at least once per 12 ho s* when the vent (s)'is being used for overpressure protection. , i

~

4

/

9 .

/4

, .* .Exespt when- the vent pathway is provided with a valve wh h =is locked, -or provided with remote position indication, sealed. or otherwise secured in the open position, then verify these valv s open at least once per.7 days.

.j

-i

~!

BEAVER VALLEY - UNIT 1 ,

3/4 4-27b Amendment No.

I

1 INSERT 1 I 3.4.9.3 An overpressure prot 9g ion system shall be OPERABLE with a maximum of one charging py capable of injecting into the RCS and the accumulators isolatedtgpt 1 and either a or b below:

a. Two power operated relief valves (PORVs) with a lift setting less than or equal to 432 psig, or

b. The RCS depressurized and an RCS vent of greater than or equal to 3.14 square inches.

APPLICABILITY: Mode 4 when any RCS cold leg temperature is less than or equal to an enable temperature of 329'F, Mode 5, Mode 6 when the reactor vessel head is on.

ACTION:

a. With two or more charging pumps capable of injecting into the RCS, immediately initiate action to verify a maximum of one charging pump is capable of injecting into the RCS or depressurize and vent the RCS through a 3.14 square inch or larger vent within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With an accumulator not isolate'd when the accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the heatup and cooldown curves, isolate the affected accumulator within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or increase the RCS cold leg temperature above the enable temperature within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or depressurize the affected accumulator to less than the maximum RCS pressure for the existing cold leg temperature allowed by the heatup and cooldown curves within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c. With one PORV inoperable in MODE 4 (when any RCS cold leg temperature is less than or equal to the enable temperature),

restore the inoperable PORV to OPERABLE status within 7 days or depressurize and vent the RCS through a 3.14 square inch or larger vent within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

d. With one PORV inoperable in MODES 5 or 6, restore the inoperable PORV to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or depressurize and vent the RCS through a 3.14 square inch or larger vent within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

e. With two PORVs inoperable, depressurize and vent the RCS through a 3.14 square inch or larger vent within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

(1) Two charging pumps may be capable of injecting into the RCS for pump swap operation for less than or equal to 15 minutes.

(2) Accumulator isolation with power removed from the discharge isolation valves is only required when the accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the heatup and cooldown curves.

BEAVER VALLEY - UNIT 1 INSERT 1 - PAGE 1

1 l

INSERT 1 (Continued)

SURVEILLANCE REQUIREMENTS 4.4.9.3.1 Verify at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that:

a. A maximum of one charging pump is capable of injecting into the RCS, and

b. Each accumulator is isolated; however, with the accumulator pressure less than the low temperature overpressure protection setpoint, the accumulator discharge isolation valves may be opened to perform accumulator discharge check valve testing.

4.4.9.3.2 When PORVs are being used for overpressure protection, demonstrate each PORV is OPERABLE by:

a. Verifying each PORV block valve is open for each required PORV at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and

b. Performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation channel, but excluding valve operation, within 31 days prior to entering a condition in which the PORV is required to be OPERABLE and placed in operation after decreasing the RCS cold leg temperature to less than or equal to the enable temperature and at least once per 31 days, and

c. Performance of a CHANNEL CALIBRATION on each required PORV actuation channel at least once per 18 months.

4.4.9.3.3 When a vent is being used for overpressure protection, verify the required vent is open:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for an open vent or unlocked open vent valve (s), except

b. At least once per 31 days for a valve which is locked or provided with remote position indication, or sealed, or otherwise secured in the open position.

BEAVER VALLEY - UNIT 1 INSERT 1 - PAGE 2

DPR-66 REACTOR COOLANT SYSTEM 3/4.4.11 RELIEF VALVES LIMITING CONDITION FOR OPERATION 73mr1 f

\.4.11 (Two) power operated relief lves (PORVs) and thei a ociated block valves shall be OPERABLE.

APPL ILITY: MODES 1, 2 and 3.

ACTION:

a. With 1 s than 2 PORV(s) operable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months e her restore two PORV to OPERABLE status or close the a ociated block valve (s) ah)d remove power from the block valve (s ; otherwise, be in at leas HOT STANDBY within the next 6 fiours and in COLD SHUTDOWN withi the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

b. With one or more lock valve (s) inoperabl , within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the block lve(s) to OPERABLE atus or close the block valve (s) and remove over from the.blo valve (s); otherwise, be

, in at least HOT ST DBY within pfia' next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ard in COLD SHUTDOWN within the foll ing 30 hoyts.

/

SURVEILLANCE REQUIREMENTS 4.4.11.1 Each PORV shall ~ demonstrated PERABLE:

a. At least onc per 31 days by perfo ance of a CHANNEL CHECK of the posit on indication, excluding valve operation and

b. By perf ance of a CHANNEL CALIBRATIO in accordance with Table 4 -7 on the operable PORV(s) Cont 1 Channel (s).

4.4.11.2 Each block valve shall be demonstrated OPE LE at least once per 92 days by operating the valve through one co late cycle of full ravel.

4.4. .3 The emergency power supply for the PORV(s) an block va. es shall be demonstrated OPERABLE at least once per 18 mont by erating the valves through a complete cycle of full travel. '

BEAVER VALLEY - UNIT 1 3/4 4-29 Amendment No.

(next page is 3/4 4-32)

PROPOSE-D

~

ZNSERT 2 3.4.11 Each power operated relief valve (PORV) and associated block valve shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

- - - - - - - - - - - - - - GENERAL NOTE - - - - - - - - - - - - - -

Separate ACTION statement entry is allowed for each PORV and block valve.

a. With one or more PORVs inoperable and capable of being manually cycled, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV(s) to OPERABLE status or close the associated block valve (s) with power maintained to the block valve (s); otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With one or two PORV(s) inoperable and not capable of being manually cycled, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months eith,er restore the PORV(s) to OPERABLE status or close the associated block valves and remove power from the block valve (s); a minimum of two PORVs are to be OPERABLE within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN'within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With one PORV inoperable and isolated, power operation may continue until the next refueling outage,

c. With three PORVs inoperable and not capable of being manually cycled, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least one PORV to OPERABLE status or close the associated block valves and remove power from the block valves and be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

d. With one block valve inoperable and open, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the block valve to OPERABLE status or place the associated PORV in manual control. Restore the block valve to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With one block valve inoperable, restore the block valve to OPERABLE status within 1 hour or close it, power opr stion may continue until the next refueling outage.

BEAVER VALLEY - UNIT 1 INSERT 2 - PAGE 1

l

' INSERT 2 (Continued)

. LIMITING CONDITION FOR OPERATION (Continued)

e. With more than one block valve inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months olther restore the block valves to OPERABLE status or place the associated PORVs in manual control. Restore at least one block valve to OPERABLE status within the next hour if.three block valves are inoperable; restore a minimum of two block valves to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

e-SURVEILLANCE REQUIREMENTS '

4.4.11.1 Each PORV shall be demonstrated OPERABLE at least once per 18 months by operating the PORV through one complete cycle of full travel using:

a) The normal air supply system, and b) The backup nitrogen supply system.

4.4.11.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by operating the valve through one complete cycle of full travel unless the block valve is closed to meet required ACTIONS b or c.

BEAVER. VALLEY - UNIT 1 INSERT 2 - PAGE 2

OPR-66 EMERGENCY CORE COOLING SYSTEMS

-SURVEILLANCE REQUIREMENTS.(Continued) penent

b. At least once per 31 days and within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after ach solution volume increase of greater than or equal to % of tank volume by verifying the boron concentration of the accumulator solution.

c. At least once per 31 days when the RCS pressure is above l 2000 psig by verifying that power to the isolation valve operator control circuit is disconnected by removal of the plug in the lock out jack from the circuit.

4.5.1.2 Each accumulator water level and pressure alarm channel ;

shall be demonstrated OPERABLE: 1

a. At least once per 31 days by the performance of a CHANNEL FUNCTIONAL TEST.

b. At least once per 18 months by the performance of a CHPNNEL CALIBRAT10N. me,eg g, 3 ,,gy,gQ, 9.3 47551.3 During normal plant cooldown and depressurization, eA.

accumulator discharge isolation valva (Mov-lSI-865A, B and C) shall be verified to be closed

and de-energized when RCS pressure is ~

ed to 1,000 t 100 psig.

[

-l I

e 6( f. 3, /,6

With the accumulator pressure less than the . low temperature i

overpressure protection setpoint the accumulator discharge

)

l isolation valves may be opened to perform accumulator discharge l ek valve testing. - l BEAVER VALLEY - UNIT 1 3/4 5-2 Amendment No.

Pactostp

. .._m _. . __ _ . __ _. _ . _ .

DPR-66 REACTOR COOLANT SYSTEM BASES 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued) vessel inside radius are essentially identical, the measured transition shift for a sample can be applied with confidence to the adjacent section of the reactor vessel. The heatup and cooldown curves must be recalculated when the ART NDT determined from the surveillance capsule is different from the calculated ART NDT f0f the equivalent capsule radiation exposure.

The pressure-temperature limit lines shown on Figure 3.4-2 for reactor criticality and for inservice leak and hydrostatic testing have been provided to assure compliance with the minimum temperature requirements of Appendix G to 10 CFR 50 for reactor criticality and for inservice leak and hydrostatic testing.

The number of reactor vessel irradiation surveillance specimens and the frequencies for removing and testing these specimens are provided in UFSAR Table 4.5-3 to assure compliance with the requirements of Appendix H to 10 CFR 50.

The limitations imposed on the pressurizer heatup and cooldown rates and spray water temperature differential are provided to assure that the pressurizer is operated within the design criteria assumed for the fatigue analysis performed in accordance with the ASME Code requirements.

Pressure-temperature limit curves shown in Figure B 3/4 4-3 were developed for the limiting ferritic steel component within an isolated reactor coolant loop. The limiting component is the steam generator channel head to tubesheet region. This figure provides the ASME III, Appendix G limiting curve which is used to define operational bounds, such that unen operating with an isolated loop the analyzed pressure-temperature limits are known. The temperature range provided bounds the expected operating range for an isolated loop.

The OPERABILITY of two PORV's or an RCS vent opening of greater than 3.14 square inches ensures that the RCS will be protected from pressure transients which could exceed the limits of Appendix G to 10 CFR Part 50 when one or more of the RCS cold legs are i the enable temperature. - The enable tamperature is defined in Standard Review Plan Section: 5.2.2 Branch Technical Position RSB 5-2 as the water tamparature correnponding to a metal temperature of at least RT 4

+ 90*F. The OPPS setpoint is determined fromanassessmentof ND steady-state pressure-temperature limits as described in UFSAR Section 4.2. Either PORV has adequate relieving capability to protect the RCS from over-pressurization when the transient is limited to either (1) the start of an idle RCP with the secondary water temperature of the steam generator 1 25'F above the RCS cold leg temperature or (2) the start of a charging pump and its injection

( into a water solid RCS. .

UP4cE MTM IMSter 3 BEAVER VALLEY - Unit 1 B 3/4 4-10 '

PROPosey

l I

INSERT 3 l l

OVERPRESSURE PROTECTION SYSTEMS BACKGROUND I The overpressure protection system (OPPS) controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure 1 boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G. The reactor vessel is the limiting RCPB component for demonstrating such protection. The maximum setpoint for the power operated relief valves (PORVs) and the maximum RCS pressure for the existing RCS cold leg temperature during cooldown, shutdown, and heatup meet the 10 CFR 50, Appendix G requirements during the OPPS MODES.

The reactor vessel material is less tough at low temperatures than at normal operating temperature. Aa the vessel neutron exposure accumulates, the material toughness decreases and becomes less resistant to pressure stress at low temperatures. RCS pressure, therefore, is maintained low at low temperatures and is increased only as temperature is increased.

The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only during shutdown; a pressure fluctuation can occur more quickly than an operator can react to relieve the condition. Exceeding the RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel. LCO 3.4.9.1, " Pressure / Temperature Limits," requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the limits.

This LCO provides RCS overpressure protection by having a minimum coolant input capability and having adequate pressure relief capacity. Limiting coolant input capability requires deactivating all but one charging pump 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 device that acts to terminate an increasing pressure event.

With minimum coolant input capability, the ability to provide core l coolant addition is restricted. The LCO does not require the makeup control system deactivated or the safety injection (SI) actuation circuits blocked. Due to the lower pressures in the OPPS MODES and the expected core decay heat levels, the makeup system can provide adequate flow via the makeup control valve and, if needed, until the charging pump is actuated by SI.

The OPPS for pressure relief consists of two PORVs with reduced lift settings or a depressurized RCS and an RCS vent of sufficient size.

Two RCS relief valves are required for redundancy. {

One RCS relief j valve has adequate relieving capability to keep from l overpressurization for the required coolant input capability. j BEAVER VALLEY - UNIT 1 INSERT 3 - PAGE 1 I

l

INSERT 3 (Continued)

PORV REOUIREMENTS As designed for the OPPS System, each PORV is signaled to open if the RCS pressure approaches a limit determined by the OPPS actuation circuit. The OPPS actuation circuit monitors RCS pressure and determines when a condition not acceptable is approached. If the indicated ' pressure meets or exceeds the OPPS actuation setpoint, a PORV is signaled to open. Having the setpoints of both valves within the limits ensure that the Appendix G limits will not be exceeded in any analyzed event. When a PORV is opened in an increasing pressure transient, the release of coolant will cause the pressure increase to slow and reverse. As the PORV releases coolant, the RCS pressure decreases until a reset pressure is reached and the valve is signaled i to close. The pressure continues to decrease below the reset '

pressure as the valve closes.

RCS VENT REQUIREMENTS Once the RCS is depressurized, a vent exposed to the containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the relieving requirements of the transient do not exceed the capabilities of'the vent. Thus, the vent path must be capable of relieving the flow resulting from the limiting OPPS mass or heat input transient, and maintaining pressure below the P/T limits. The required vent capacity may be provided by one or more vent paths.

For an RCS vent to meet the flow capacity requirement, it may be satisfied by removing a pressurizer safety valve or establishing an opening between the RCS and the containmen'c atmosphere of the required size through any positive means available which cannot be inadvertently defeated. The vent path (s) must be above the level of reactor coolant, so as not to drain the RCS when open.

APPLICABLE SAFETY ANALYSES Safety analyses demonstrate that the reactor vessel is adequately protected against exceeding the P/T limits when low RCS temperature conditions exist. At the enable temperature and below, overpressure ;

prevention is provided by two OPERABLE RCS relief valves or a j depressurized RCS and a sufficient sized RCS vent. ,

The actual temperature at which the pressure in the P/T limit curve l falls below the OPPS setpoint increases as the reactor vessel material toughness decreases due to neutron embrittlement. Each time the heatup and cooldown curves are revised, the OPPS must be i re-evaluated to ensure its functional requirements can still be met.

BEAVER VALLEY - UNIT 1 INSERT 3 - PAGE 2

INSERT 3 (Continued)

APPLICABLE SAFETY' ANALYSES (Continued) l The heatup and cooldown curves represent the Appendix G limits that define OPPS operation. Setpoint calculations correlated to RCS temperature define acceptable OPPS setpoints for steady-state pressure-temperature limits based on Revision 2 of NRC Regulatory Guide 1.99. Any change to the RCS that may affect OPPS operation must be evaluated against the analyses to determine the impact of the change on the OPPS acceptance limits.

Transients that are capable of overpressurizing the RCS are categorized as either mass or heat input transients, examples of which follow:

MASS INPUT TYPE TRANSIENTS

a. Inadvertent safety injection; or

b. Charging / letdown flow mismatch.

HEAT INPUT TYPE TRANSIENTS i

a. Inadvertent actuation of pressurizer heaters;

b. Loss of RHR cooling; or

c. Reactor coolant pump (RCP) startup with temperature asymmetry within the RCS or between the RCS and steam generators.

The following are required during the OPPS MODES to ensure that mass and heat input transients do not occur, which either of the OPPS overpressure protection means cannot handle:

a. Deactivating all but one charging pump OPERABLE;

b. Deactivating the accumulator discharge isolation valves in their closed positions; and

c. Disallowing start of an RCP if secondary temperature is more than 25'F above primary temperature in any one loop. LCO 3.4.1.6, " Reactor Coolant Pump Startup," provides this protection.

The analyses demonstrate that either one RCS relief valve or the

'depressurized RCS and RCS vent can maintain the RCS pressur e below the limits when only one charging pump is actuated by SI. Thus, the LCO allows only one charging pump OPERABLE during the OPPS MODES.

Since neither one RCS relief valve nor the RCS vent can handle a full SI actuation, the LCO also requires the accumulators isolated.

BEAVER VALLEY - UNIT 1 INSERT 3 - PAGE 3

4 INSERT 3 (Continued)

HEAT INPUT TYPE TRANSIENTS (Continued)

The isolated accumulators must have their discharge valves closed with power removed. Fracture mechanics analyses established the temperature of OPPS Applicability at the enable temperature.

PORV PERFORMANCE The fracture mechanics analyses show that the vessel is protected when the PORVs are set to open at or below the limit. The setpoint is derived by analyses that model the performance of the OPPS assuming the limiting OPPS transient of SI actuation of one charging pump. These analyses consider pressure overshoot and undershoot beyond the PORV opening and closing, resulting from signal processing and valve stroke times. The PORV setpoints at or below the derived limit ensures the P/T limits will be met.

The PORV setpoint will be updated when the revised P/T limits conflict with the OPPS analysis limits. The P/T limits are periodically modified as the reactor vessel material toughness decreases due to neutron embrittlemeqt caused by neutron irradiation. Revised limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens. The Bases for LCO 3.4.9.1, " Pressure / Temperature Limits," discuss these examinations.

The PORVs are considered active components. Thus, the failure of one PORV is assumed to represent the worst case, single active failure.

RCS VENT PERFORMANCE With the RCS depressurized, analyses show that a PORV or equivalent opening with a vent size of 3.14 square inches is capable of mitigating the allowed OPPS overpressure transient. The capacity of a vent this size is greater than the flow of the limiting transient for the OPPS configuration, SI actuation with one charging pump OPERABLE, maintaining RCS pressure less than the maximum pressure on the P/T limit curve.

The RCS vont size is based on the PORV size, therefore, the vent is bounded by the PORV analyses.

The RCS vent is passive and is not subject to active failure.

ISD This LCO requires that the OPPS is OPERABLE. The OPPS is OPERABLE when the minimum coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the limits as a result of an operational transient.

BEAVER VALLEY - UNIT 1 INSERT 3 - PAGE 4

INSERT 3 (Continued)

LCO (Continued)

To limit the coolant input capability, the LCO requires one charging pump capable of injecting into the RCS and all accumulator discharge isolation valves closed and immobilized. The LCO is qualified by a note that permits two pumps capable of RCS injection for less than or equal to 15 minutes to allow for pump swaps.

The LCO is also qualified by a note stating that accumulator isolation with power removed from the discharge isolation valves is only required when the accumulator pressure is greater than or at the maximum RCS pressure for the existing temperature, as allowed by the P/T limit curves. This note permits the accumulator discharge isolation valve surveillance to be performed only under these pressure and temperature conditions.

The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

a. Two OPERABLE PORVs; a PORV is OPERABLE for OPPS when its block valve is open, its lift setpoint is set to the limit and testing proves its ability to open at this setpoint, and motive power is available to the two valves and their control circuits; or

b. A depressurized RCS and an RCS vent.

An RCS vent is OPERABLE when open with an area of 3.14 square inches.

Each of these methods of overpressure prevention is capable of mitigating the limiting OPPS transient.

APPLICABILITY This LCO is applicable in MCDE 4 when any RCS cold leg temperature is less than or equal to the enable temperature, in MODE 5, and in l MODE 6 when the reactor vessel head is on. When the reactor vessel !

head is off, overpressurization ca.nnot occur.

Low temperature overpressure prevention is most critical during U shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event. ,

I ACTION

a. With two or more charging pumps capable of injecting into l the RCS, RCS overpressurization is possible.

To immediately initiate action to restore restricted coolant input capability to the RCS reflects the urgency of removing the RCS from this condition.

BEAVER VALLEY - UNIT 1 INSERT 3 - PAGE 5 l

INSERT 3 (Continued)

ACTION (Continued)

b. An unisolated accumulator requires isolation within i hour.

This is only required when the accumulator pressure is at or more than the maximum RCS pressure for the existing temperature allowed by the P/T limit curves.

If isolation is needed and cannot be accomplished in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the ACTION provides two options, either of which must be performed in the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . By increasing the RCS temperature to more than the enable temperature, the accumulator pressure cannot exceed the OPPS limits if the accumulators are fully injected. Depressurizing the accumulators bel'w the OPPS limit also gives this protection.

The completion times are based on operating experience that these activities can be accomplished in these time periods indicating that an event requiring OPPS is not likely in the allowed times,

c. In MODE 4 when any RCS cold leg te'mperature is less than or equal to the enable temperature, with one required RCS relief valve inoperable, the RCS relief valve must be restored to OPERABLE status within a completion time of 7 days. Two RCS relief valves are required to provide low temperature overpressure mitigation while withutanding a single failure of an active component.

The completion time considers the factn that only one of the RCS relief valves is required to mitigate an overrressure transient and that the likelihood of an active failure of the remaining valve path during this time period is very low. If plant operation results in transitioning to MODE 5, the completion time to restore an inoperable PORV may not exceed 7 days as required by this ACTION.

d. The consequences of operational events that will overpressurize the RCS are -more severe at lower temperature. Thus, with one of the two RCS relief valves inoperable in MODE 5 or in MODE 6 with the head on, the completion time to restore two valves to OPERABLE status is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The completion time represents a reasonable time to investigate and repair several types of relief valve i failures without exposure to a lengthy period with only one )

OPERABLE RCS relief valve to protect against overpressure events. If a PORV is inoperable when the plant enters MODE 5 from MODE 4, the completion time to restore an inoperable PORV changes to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months but tha cumulative inoperable time may not exceed 7 days before taking. action i to depressurize and vant.

i BEAVER VALLEY - UNIT 1 INSERT 3 - PAGE 6

INSERT 3 (Continued)

ACTION (Continuedl

e. The RCS must be depressurized and a vent must be established within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when both required RCS relief valves are inoperable. The vent must be sized greater than or equal to 3.14 square inches to ensure that the flow capacity is greater than that required for the worst. case mass input transient reasonable during the applicable MODES This action is needed to protect the RCPB from a low temp.rature overpressure event and a possible brittle failure of the reactor vessel.

The completion time considers the time required to place the plant in this condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements.

SURVEILLANCE REOUIREMENTS (SR)

SR 4.4.9.3.1 ,

To minimize the potential for a low temperature overpressure event by limiting the mass input capability, a maximum of one charging pump is OPERABLE with the others verified deactivated with power removed and the accumulator discharge isolation valves are verified closed and locked out.

The frequency of 12 hours is sufficient, considering other indications and alarms available to the operator in the control room, to verify the required status of the equipment.

SR 4.4.9.3.1.b allows opening the accumulator discharge isolation valves to perform accumulator discharge check valve testing.

SR 4.4.9.3.2 The PORV block valve must be verified open every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to provide the flow path for each required PORV to perform its function when actuated. The valve must be remotely verified open in the main control room. This surveillance is performed if the PORV satisfies the LCO.

The block valve is a remotely controlled, motor operated valve. The power to _the valve operator is not required removed, and the manual operator is not required locked in the inactive position. Thus, the block valve can be closed in the event the PORV develops excessive (sticks open) after relieving- an leakage or does not close i overpressure situation. l BEAVER VALLEY - UNIT 1 INSERT 3 - PAGE 7

_ INSERT 3 (Continuedl SURVEILLANCE REOUIREMENTS (SR) (Continued)

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months frequency is considered adequate in view of other administrative controls available to the operator in the control room, such as valve position indication, that verify that the PORV block valve remains open.

The SR is required to be performed prior to entering the condition for the OPPS to be OPERABLE. This assures low temperature overpressure protection is available when the RCS cold leg temperature is less than or equal to the enable temperature.

Performing the surveillance every 31 days on each required PORV permits verification and adjustment, if necessary, of its lift setpoint, and considers instrumentation reliability which has been shown through operating experience to be acceptable. The CHANNEL FUNCTIONAL TEST will verify the setpoint is within the allowed maximum limits. PORV actuation could depressurize the RCS and is not required.

Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 months to ad that it responds and the valve opens with'just therequired in the whole channel so range and accuracy to known input.

SR 4.4.9.3.3 The RCS vent of greater than or equal to 3.14 square inches is proven OPERABLE by verifying its open condition either:

a. Once overy 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for an open vent or valve that cannot be locked, except

b. Once every 31 days for a valve that is locked, or provided with remote position indication, or sealed, or secured in position. A removed pressurizer safety valve fits this category.

The passive vent arrangement must only be open to be OPERABLE. This surveillance is required to be performed if the vent is being used to satisfy the pressure relief requirements of the LCO.

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BEAVER VALLEY - UNIT 1 INSERT 3 - PAGE 8 j

DPR-66 PEACTOR COOLANT SYSTEM 3ASES J/4.4.10 STRUCTURAL INTEGBITY The inservice inspection and testing programs for ASME Code Class 1, 2, and 3 components ensure that the structural integrity and operational readiness of these components will be maintained at an acceptable level throughout the life of the plant. These programs are in accordance with Section XI of the ASME Boiler and Pressure Vcosal Code and applicable Addenda as required by 10 CFR Part 50.55a(g) except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50. 55a (g) (6) (1) .

3/4.4.11 PEtirr VArvrs gg y 9

~

The relief valves have remotely operated block valves to provide a positive shutoff capability should a relief valve become inoperable.j The electrical power for both the relief valves and the bl h valves is capable of being supplied from an emergency power sourc6 to ensure)

\sqhs ability to seal this possible RCS leakage path, d 3 / 4. 4.12 REACTOR COOLANT SYSTEM VENTS Reactor Coolant System Vents are provided to exhaust noncondensible gaces and/or steam from the primary system that could inhibit natural circulation core cooling. The OPERAF,ILITY of at least one reactor coolant system vant path from the reactor vessel head and the l rossurizar steam space, ensures the capability exists to perform '

his function.

The valve redundancy of the reactor coolant system vent paths serves to minimize the probability of inadvertent or irreversible actuation ,

while ensuring that a single failure of a vent valve, power supply or l control system does not prevent isolation of the vent path. I The function, capabilities, and testing requirements of the reactor coolant system vent systems are consistent with the requirements of Item II.B.1 of NUREG-0737, " Clarification of TMI Action Plan Requirements", November 1980.

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DEAVER VALLEY - UNIT 1 B 3/4 4-11 At0P01Eb

TNSERT 4 !

l HACKGROUND I The Pressurizer is equipped with two types of devices for pressure relief: pressurizer safety valves and PORVs. The PORVs are air operated valves that are controlled to open at a specific set pressure when the pressurizer pressure increases and close when the pressurizer pressure decreases. The PORVs may also be manually I operated from the control roor.

Block valves, which are norma.lly open, are located between the pressurizer and the POPVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room.

A stuck open PORV is, in effect, a small break loss of coolant !

accident (LOCA). As such, block valve closure terminates the RCS depressurization and coolant inventory loss.

The PORVs and their associated block valves may be used by plant ;

operators to depressurize the RCS to recover from certain transients j if normal pressurizer spray is not available. Additionally, the i series arrangement of the PORVs and their block valves permit l

performance of certain surveillances on the valves during power '

operation.

The PORVs may also be used for feed and bleed core cooling in the case of multiple equipment failure events that are not within the design basis, such as a total loss of feedwater.

The PORVs, their block valves, and their controls are powered from emergency power sources in the event of a loss of offsite power. Two PORVs and their associated block valves are powered from two separate safety trains.

The plant has three PORVs, each having a relief capacity of 210,000 lb/hr at 2350 psig. The functional design of the PORVs is based on maintaining pressure below the high pressure reactor trip setpoint.

In addition, the PORVs minimize challenges to the pressurizer safety !

valves and also may be used for low temperature overpressure protection (OPPS). See LCO 3.4.9.3, " Overpressure Protection System."

APPLICABLE SAFETY ANALYSES Plant operators employ the PORVs to depressurize the RCS in response to certain plant transients if normal pressurizer spray is not available. For the Steam Generator Tube Rupture (SGTR) event, the safety analysis assumes that manual operator actions are required to mitigate the event. A loss of offsite power is assumed to accompany the event, and thus, normal pressurizer spray is unavailable to 1

i BEAVER VALLEY - UNIT 1 INSERT 4 - PAGE 1 '

INSERT 4 (Continued)

APPLICABLE SAFETY ANALYSES (Continued) reduce RCS pressure. The PORVs are assumed to be used for RCS depressurization, which is one of the steps performed to equalize the primary and secondary pressures in order to terminate the primary to secondary break flow and the radioactive releases from the affected steam generator.

The PORVs are used in safety analyses for events that result in increasing RCS pressure for which departure from nucleate boiling ratio (DNBR) criteria are critical. Certain analyses have been performed to study the effects on primary pressure assuming PORV actuation. The results of the loss of external load and/or a turbine trip event indicate the primary pressure remains within the design limits and the DNBR is maintained within the acceptance criteria.

LCO The LCO requires the PORVs and their associated block valves to be OPERABLE for manual operation to mitigate the effects associated with an SGTR. ,

By maintaining at least two PORVs and their associated block valves OPERABLE, redundancy has been provided. The block valves are available to isolate the flow path through either a failed open PORV or a PORV with excessive leakage. Satisfying the LCO helps minimize challenges to fission product barriers.

APPLICABILITY In MODES 1, 2, and 3, the PORV and its block valve are required to be OPERABLE to limit the potential for a small break LOCA through the flow path. The most likely cause for a PORV small break LOCA is a result of a pressure increase transient that causes the PORV to open. Imbalances in the energy output of the core and heat removal .

by the secondary system can cause the RCS pressure to increase to the I PORV opening setpoint. The most rapid increases will occur at the I higher operating power and pressure conditions of MODES 1 and 2. The I PORVs are also required to be OPERABLE in MODES 1, 2, and 3 to l minimize challenges to the pressurizer safety valves. l i

Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. Therefore, the LCO is applicable in MODES 1, 2, and 3. The LCO is not applicable in MODE 4 when both pressure and core energy are decreased and the pressure surges become much less significant. The PORV setpoint is reduced for OPPS in MODES 4 (below the enable temperature), 5, and 6 with the reactor vessel head in place. LCO 3.4.9.3 addresses the PORV requirements in these MODES.

BEAVER VALLEY - UNIT 1 INSERT 4 - PAGE 2

INSERT 4 (Continued)

ACTION A General Note provides clarification that all pressurizer PORVs and block valves are treated as separate entities, each with separate completion times (i.e., the completion time is on a component basis).

a. With the PORVs inoperable and capable of being manually cycled, either the PORVs must be restored or the flow path isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The block valves should be closed but power must be maintained to the associated block valves, since removal of power would render the block valve inoperable. Although a PORV may be designated inoperable,-

it may be able to be manually opened and closed, and therefore, able to perform its function. PORV inoperability may be due to seat leakage, instrumentation problems related to PORV accident monitoring instruments identified in LCO 3.3.3.8, or other causes that do not prevent manual use and do not create a possibility for a small break LOCA. If the position indication is inoperable, then the PORVs are inoperable. For these reasons, the block valve shall be closed but the ACTION requires _p'ower be maintained to the valve. Automatic control problems and related instrumentation problems would not render the PORVs inoperable. Accident analyses assume manual operation of the PORVs and does not take credit for automatic actuation.

This_ condition is only intended to permit operation of the plant for a limited period of time not to exceed the next u refueling outage (MODE 6) so that ' maintenance can be performed on the PORVs to eliminate the seat leakage condition. Normally, the PORVs should be available for automatic mitigation of overpressure events and should be i returned to OPERABLE status prior to entering startup (MODE 22 ;

Quick access to the PORV for pressure control can be made )

when power remains on the closed block valve. The completion time- of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is based on plant operating experience that has shown that minor problems can be corrected or closure accomplished in this time period.

b. With one or two PORV(s) inoperable and not capable of being manually cycled, the PORV(s) must be either restored or isolated by closing the associated block valve and removing the power to the associated block valve. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on challenges to the PORVs during this time period, and provides the operator adequate time to correct the situation. If the inoperable valve (s) cannot be restored to OPERABLE status, the PORV(s) must be isolated within the specified time. Because there l is at least one PORV that remains OPERABLE, an additional 72 I

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BEAVER VALLEY - UNIT 1 INSERT 4 - PAGE 3 1

INSERT 4 (Continued)

ACTION (Continued) hours is provided to restore a minimum of two PORVs to OPERABLE status. If a minimum of two PORVs cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply. Two OPERABLE PORVs provide redundancy to allow continued operation until the next refueling outage to perform maintenance on the inoperable valve and return it- to OPERABLE status.

c. If three PORVs are inoperable and not capable of being manually cycled, it is necessary to either restore at least one valve within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or isolate the flow path by closing and removing the power to the associated block valves. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. If one PORV is restored, then the plant will be in a less limiting ACTIN! statement with the time clock started at the original declaration of having three PORVs inoperable. If no PORVs are restored within the completion time, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed completion times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, maintaining PORV OPERABILITY may be required. See LCO 3.4.9.3.

d. If one block valve is inoperable and open, then it is necessary to either restore the block valve to OPERABLE status within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or place the associated PORV in manual control. The prime importance for the capability to close the block valve is to isolate a stuck open PORV. Therefore, if the block valve cannot be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the required action is to place the PORV in manual control to preclude its automatic opening for an overpressure event and to avoid the potential for a stuck open PORV at a time that the block valve is inoperable. If the block valve is inoperable, it is necessary to restore the block valve to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or close it. If block valve instrumentation related to accident monitoring instrumentation identified in LCO 3.3.3.8 is determined to be inoperable, then the block valve shall be declared inoperable. Closing the block valve precludes the need to place the PORV in manual control since it is isolated from the system. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time period, and BEAVER VALLEY - UNIT-1 INSERT 4 - PAGE 4

INSERT 4 (Continued) l ACTION (Continued) provides the operator time to correct the situation.

Because at least one PORV remains OPERABLE, the operator is permitted a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable open block valve to OPERABLE status. If it cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply in order to avoid continuous opere. tion without a redundant ability to isolate this PORV flow path. If the block valve is restored within the complet. ion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the power will be restored and the PORV restored to OPERABLE status. With one block valve inoperable and closed, there still remains two PORV flow paths. This redundancy will allow continued operation until the next refueling outage to perform maintenance on the inoperable valve and return it to OPERABLE status.

e. If more than one block valve is inoperable, it is necessary to either restore the block valves within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or place the associated PORVs in manual control and restore at least one Block valve within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (and restore a minimum of two block valves within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s]. Two OPERABLE PORVs provide redundancy to allow continued operation until the next refueling- outage to perform maintenance on the inoperable valve and return it to OPERABLE status. The completion times are reasonable, based on the small potential for challenges to the system during this time and provide the operator time to correct the situation. If the required actions are not met, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed completion times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, maintaining PORV OPERABILITY may be required. See LCO 3.4.9.3.

SURVEILLANCE REOUIREMENTS (SR)

SR 4.4.11.1 This surveillance requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be manually actuated for mitigation of an SGTR. The frequency of 18 months is based on a typical refueling cycle and industry accepted practice. Cycling the PORVs using both the normal air supply system BEAVER VALLEY - UNIT 1 INSERT 4 - PAGE 5

INSERT 4 (ContinuedL l

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SURVEILLANCE REOUIREMENTS (SR) (Continued) and the backup nitrogen supply system actuates the solenoid control valves and check valves to ensure the PORV control system will actuate properly when called upon. Testing in this manner assures each component within the PORV control system necessary to support )

PORV operation has been determined to function satisfactorily. '

SR 4.4.11.2 Block valve cycling verifies that the valve (s) can be closed if needed. The basis for the frequency of 92 days is the ASME Code,Section XI. If the block valve is closed to isolate a PORV that is capable of being manually cycled, the OPERABILITY of the block valve is of importance, because opening the block valve is necessary to permit the PORV to be used for manual control of reactor pressure.

If the block valves are closed to isolate otherwise inoperable PORVs, the maximum completion time to restore one PORV and open the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , which is well within the allowable limits (25%) to extend the block valve frequency of 92 days. Furthermore, these test requirements would be completed by the reopdning of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e.,

completion of the required actions fulfills the SR).

This SR is not required to be met with the block valve closed, in accordance with required ACTION b or c of this LCO.

BEAVER VALLEY - UNIT 1 INSERT 4 - PAGE 6

ATTACHMENT A-2 Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification Change No. 49 MARKED-UP PAGES The following is a list of the affected pages:-

Affected Pages: 3/4 1-10 3/4 1-11 3/4 3-57 l 3/4 4-35 !

3/4 4-36 i 3/4 4-39 l 3/4 5-2 l B 3/4 4-14 I B 3/4 4-15 B 3/4 4-16 6-19 1

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NPF-73 '

1 REACTIVITY CCNTROL $YSTEMS CHARGING PUMP-$ HUT 00%N I

LIMIT:NG CONDITION FOR OPERATION Atlearf 3.1.2.3 gne charging pum Min the boron injection flow path required by Specification 3.1.2.1orgowgeadgafety/njectiongump(withanopen Reactor Coolant System vent of greater than or equal to 3.14 square inches) shall be OPERABLE and capable of being powered from an OPERABLE emergency bus.

APPLICABILITY: MODES 4, 5 and 6 ACTION:

With none of the above pumps OPERABLE, suspend all operations involving CORE ALTERATIONSorpositivereactivitychangesuntilonechargingpumporgowgead gafety/njectionpumpisrestoredtoOPERABLEstatus.

i SURVEILLANCE REQUIREMENTS ttdtt han et t smal'f5 4.1.2.3.1 e above required charging pump shall be demonstrated OPERABLE by verifyin . that on recirculation flow. the pump develops a differential pres-

-sure of > 2437 psid when tested pur,sp*nt to Speciff,pation 4.0.5.

~

meM 18 Sancs ro t* a 1 >'o n 3. 't. # 1

[4.1.2.3.2 Allchargingpumps,excepttheaboverequiredchargingpump,shall) be demonstrated inoperable

by verifying that the control switches are placed in the PULL-TO-LOCK position and tagged within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entering MODE 4 from MODE 3 or prior to the temperature of one or more of the RCS cold legs decreasing below 325*F, whichever comes first, and at least once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months sj t thereafter.

4.1.2.3./AWhen the gowgead gafety/njection pump is used in lieu of a charg-ingpump,thegowgeadfafety/njectionpumpshallbedemonstratedOPERABLEby:

a. Verification of an OPERABLE RWST pursuant to 4.1.2.7 and 4.1.2.8 b.

VerificationofanOPERABLE/owgeadgafety)hjection/umppursuant l to Specification 4.5.2.b.2,

c. Verification of an OPERABLE gowgead gafety /njection flow path from 1 I

the RWST to the Reactor Coolant System once per shif t, and

d. Verific'ation that the vent is open et ' crit err ::r l hour:;. "

l CM a cc o#*da Med W//A V.V. % J. 3.A ba lefe fAninoperablepumpmaybeenergizedfortestingprovidedthedischargeofthe pump has been isolated from the RCS by a closed isolation valve.with power bremovedfromthevalveoperator,orbyamanualisolationvalvelockedi he closed oosition. -

"Ex dpt wnen tne vent path is provided with a valve which is locked or providea with remote position indication, or sealed, or otherwise secured in the open sition, then verify these valves open at least once per 7 days.

Nte ln W;h

k. cW % pu.,ps OPMecu .Q,a spebFice % 3.H.J.

p BEAVER VALLEY - UNIT 2 3/4 1-10' Amendment No.

MOMCEb

L' NPF-73 REACTIVITY CONTROL SYSTEMS '

CHARGING PUMPS-OPERATING l l

LIMITING CONDITION FOR OPERATION 3.1.2.4 At least two charging ps shall be OPERABLE

) !

APPLICABILITY: MODES 1, 2 and 3 . .

I 1 ACTION:

efcggy With only one charging pump OPERA 8LE, re ore at least two charging pumps to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be i at least HOT STANOBY and borated to a SHUTDOWN MARGIN equivalent to at least ak/k at 200*F within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; I restore at least two charging pumps to OPERABLE status within the next 7 days or be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.1.2.4.1 At least two charging pumps shall be demonstrated OPERABLE by verifying, that on recirculation flow, each pump develops a differential pressure of > 2437 psid when tested pursuant to Specification 4.0.5. l t greafte & ct egaal ti l

7, y', 9, 3 (0XThe provisions of Sp ifications 3.0.4 and 4.0.4 are not applicable for entry I into MODE 3 for the entrifugal charging pump declared inoperable pursuant to :

Specification 4.1...'

?-provided that the centrifugal charging pump is restored I to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or prior to the temperature of one or more i

of the RCS cold legs exceeding 375'F, whichever comes first.

BEAVER VALLEY - UNIT 2 3/4 1-}1 ffnposed Ldob,h 1 1

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I NPF-73 INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.8 The accident monitoring instrumentation channels shown in Table 3.3;11 I shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTION

a. With the number of OPERABLE accident monitoring instrumentation channels !

less than the Total Number of Channels shown in Table 3.3-11, either I restoretheinoperablechannel(s)toOPERABLEstatuswithin7daysorbe in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months e n ept f r th- P^P3 hich m SpuG&}a k 3,- Ybe H is;1ated in accordance when deludnim Ac77w.s %ILs withy Specific a d'c. &tiec :.4.11.[fv

b. With the number of OPERABLE accid (nt monitoring instrumentatio)n channels less than the Minimum Channels OPERABLE requirements of Table 3.3 11, I either restore the inoperable channel (s) to OPERABLE status withi;n 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c. With the number of OPERABLE Reactor Coolant System Subcooling Margin Monitor instrumentation channels less than the Minimum Channels OPERABLE requirements of Table 3.3-11, either restore the inoperable channel (s) to I OPERABLE status within 7 days or be in a least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

d. The provisions of Specification 3.0.4 are not applicable.

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SURVEILLANCE REOUIREMENTS 4.3.3.8 Each accident monitoring instrumentation channel shall be demonstrated !

OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-7. ;

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8EAVER VALLEY - UNIT 2 3/4 3-57 Amendment No. ,

PROP 6 SED i

NPF-73 REACTOR COOLANT SYSTEM I l

OVERPRES$URE PROTECTION SYSTEMS f MSEA T l LIMITING CONDITION FOR OPERATION / I V

s 4.9.3 At least one of the following Overpressure Protection Systems (OPP 1 be OPERA 8LE:

Two power-operated relief valves (PORVs) with nominal' maxi allow-able lift settings which vary with the RCS temperature and ich do t excaed the l' sits established in FIGURE 3.4-4, or

b. A tor Coolant Systes vent of > 3.14 square inches.

APPLICA81LITY: in the temperature of one or more of the no isolated RCS cold legs is 5,3

F.

ACTION:

4

a. With one POW noperable, either restore inoperable PO W to OPERA 8tE status ithin 7 days' or depressur ze and vent the RCS -

through a 3.14 s re inch vent (s) withi the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; maintain the RCS i a vented condition til both POWS have been restored to 0PE LE status. Re er to' Technical Specification 3.4.1.6 or further.I itations..

b. With both POWS inoperabl dep surize and vent the RCS through a 3.14 square inch vent (s) i n 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ; maintain the RCS ~in a vented condition until both s have been restored to OPERA 8LE status,

c. In the event eithe'r the , Ws or an RCS pressure transt RCS vent (s) are used to mitigate t, a Specia Report shall be prepared and submitted to the Come sion pursuant Specification 6.9.2 within 30 days. The repo shall' describe t circiastances initiating the transient, the aff of the PORVs or vent (s) on the transient, and any correcti action necessary to p ent recurrence.

d. The previst of Specification 3.0.4 are not licable.

C11RVEIllAsare egntif g I

./

4.4.9.3.1 Each shall be demonstrated OPERA 8LE SY:

a. Pe ormance of a CHANNEL FUNCTIONAL TEST on the PORY act tion channel, but excluding valve operation, within 31 days prior to ent ng a !

' condition in which the PORY is required OPERABLE and at les once per 31 days thereafter when the PORV is required OPERABLE..

i

b. \ l Performance of a CHANNEL CALIBRATION on the PORY actuation channel i at least once per 18 months. i l

BEAVER VALLEY - UNIT 2 3/4 4-35 PRONSED

l bcORCOOLANTSYSTEM MN I k !

$URVF LANcf RE0!!fREWENTS(continued)

c. /

Verifying the PORV i';olation valve is open at least once per /

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months when the PORY is being used for overpressure protection /

4.4.9.3.2 T /

least once pe > 3.14 square inch RCS vent (s) shall be verified to be open' at protection. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " when the vent (s) is being used for overpressury

/

/ '

/

\

N

, N .

\

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.

BEAVER VALLEY - UNIT 2 3/4 4-36 hh t * -

%dh5&D

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INSERT 1 1 3.4.9.3 An overpressure protectigg system shall be OPERABLE with a maximum of one charging pg the RCS and the accumulators isolatedtgp i ) capable of injecting into 1 and either a or b below:

a. Two power-operated relief valves (PORVs) with nominal l maximum lift settings which vary with the RCS temperature I and which do not exceed the limits established in Figure 3.4-4, or

b. The RCS depressurized and an RCS vent of greater than or equal to 3.14 square inches.

APPLICABILITY: MODE 4 when any RCS cold leg temperature is less than or equal to an enable temperature of 350*F, MODE 5, MODE 6 when the reactor vessel head is on.

ACTION:

a. With two or more charging pumps capable of injecting into the RCS, immediately initiate action to verify a maximum of one charging pump is capable of injecting into the RCS or depressurize and vent the RCS through a 3.14 square inch or larger vent within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ,

b. With an accumulator not isolated when the accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the heatup and cooldown curves, isolate the affected accumulator within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or increase the RCS cold leg temperature above the enable temperature within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or depressurize the affected accumulator to less than the maximum RCS pressure for the existing cold leg temperature allowed by the heatup and cooldown curves within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c. With one PORV inoperable in MODE 4 (when any RCS cold leg i temperature is less than or equal to the enable temperature), restore the inoperable PORV to OPERABLE status within 7 days or depressurize and vent the RCS through a j 3.14 square inch or larger vent within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . '

The provisions of Specification 3.0.4 are not applicable when in this action.

1 (1) Two charging pumps may be capable of injecting into the RCS'for l pump swap operation for less than or equal to 15 minutes. All l charging pumps may be capable of injecting into the RCS for less l than or equal to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months immediately following a change from MODE 3 to MODE 4 or prior to the temperature of one or more of j the RCS cold legs decreasing below 325'F, whichever comes first.

(2) Accumulator isolation with power removed from the discharge isolation valves is only required when the accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the heatup and cooldown curves.

BEAVER VALLEY - UNIT 2 INSERT 1 - PAGE 1

INSERT 1 (Continued)

ACTION (Continued)

d. With one PORV inoperable in MODES 5 or 6, restore the inoperable PORV to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or depressurize and vent the RCS through a 3.14 square inch or larger vent within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

e. With two PORVs inoperable, depressurize and vent the RCS through a 3.14 square inch or larger vent within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

SURVEILLANCE REQUIREMENTS l

4.4.9.3.1 Verify at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that:

a. A maximum of one charging pump is capable of injecting into the RCS, and

b. Each accumulator is isolated; however, with the accumulator pressure less than the low temperature overpressure protection setpoint, the accumulahor discharge isolation valves may be opened to perform accumulator discharge check valve testing.

4.4.9.3.2 When PORVs are being used for overpressure protection, demonstrate each PORV is OPERABLE by:

a. Verifying each PORV block valve is open for each required-PORV at-least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and

b. Performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation channel, but excluding valve operation, within 31 days prior to entering a condition in which the PORV is required to be OPERABLE and placed in operation after decreasing the RCS cold leg temperature to less than or equal to the enable temperature and at least once per 31 days, and

c. Performance of a CHANNEL CALIBRATION on each required PORV actuation channel at least once per 18 months.

4.4.9.3.3 hhen a vent is being used for overpressure protection, verify the required vent is open:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for an open vent or unlocked open vent valve (s), except

b. At least once per 31 days for a valve which is locked, or provided with remote position indication, or sealed, or otherwise secured in the open position.

I BEAVER VALLEY - UNIT 2 INSERT 1 - PAGE 2 '

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NPF-73 l

REACTOR COOLANT SYSTEM

_3/4.4.11 RELIEF VALVES i g ING' CONDITION FOR OPERATION s..A 3.4.11 AM-power-operated relief valve)( (PORVy and thi associated block I valveKshallbeOPERA8LE.

u APPLICA8ILITY: MODES 1, 2, and 3 l t

ACTION: A&fUlf id177/ NNU A -- ,

s 1

a. With one or more PO W(s) inoperable, because of excessive seat '

leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the POW (s) to OPERA 8LE status N or close the associated block valve (s); otherwise, be in at least \

HOT STAW8Y within following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within thei j

b. With one or two POW (s) inoperable as a result of causes other than excessive seat leakage, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore.the PO W(s) to : !

OPERA 8LE status or c ose the associated block valve (s) and remove. !

power free-the block valve (s). !

c. With all three POWS inoperable due to causes other than excessive ,

seat. leakage, within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months either restore one PO W to 0PERA8LE status or be in HDT-STA MOY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and COLD SHUTOOWN

[i within.the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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d. With one or more block valve (s) inoperable, within 1 hour: (1) re- !

i store the block valve (s) to OPERABLE status, or close the block valve (s) and remove power from the block valve (s), or close the PORV; and (2) apply the ACTION b. or c. above, as appropriate, .for the [

isolated POW (s). I

\ e. The provisions of Specification 3.0.4 are not applicable.'

suavtiLLAmcr asourasuruTs

~{

t 4.4.11.1 In addition to the requiresea.ts of Specification 4.0.5, each PORV shall be demonstrated OPERA 8LE at least once per la months by:

a. Performance of a CHAle6EL CALIBRATION, and

b. ~0perating the valve through one complete cycle of full travel.

4.4.11.2 Each block valve shall be demonstrated OPERA 8LE at least once per 92 da s by operating the valve through one complete cycle of full travel unless

\ of c. or d. inb.,Specification 3.4.11.the b ock valve is closed with power removed in ACTION

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. 7 BEAVER VALLEY - UNIT 2 3/4 4-39

. tw.o posa

INSERT 2 ACTION:

- - - - - - - - - - - - - - - GENERAL NOTE - - - - - - - - - - - - -

Separate ACTION statement entry is allowed for each PORV and block valve.

a. With one PORV inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV and to OPERABLE status or close the associated block valve remove power from the block valve; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Power operation may continue until the next refueling outage,

b. With two PORVs inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORVs to OPERABLE status or close the associated block valves and remove power from the block valves; restore at least one PORV to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6, hours and in HOT SHUTDOWN within the.following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

c. With three PORVs inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least one PORV to OPERABLE status or close the associated block valves and remove power from the block valves and be in HOT STANDBY within the next 6 hours and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

d. With one block valve inoperable and open, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the block valve to OPERABLE status or place the associated PORV in manual control. Restore the block valve to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within within the the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With one block valve inoperable, i hour or restore the block valve to OPERABLE status within close it, power operation may continue until the next refueling outage.

e. With more than one block valve inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the block valves to OPERABLE status or place the associated PORVs in manual control.

block valve Restore at least one to OPERABLE status within block valves are inoperable; restore a minimum the next hour if three valves to OPERABLE of two block HOT STANDBY within status within 72 hours; otherwice, be in the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN-within the followini 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

BEAVER VALLEY - UNIT 2 INSERT 2 - PAGE 1

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INSERT 2 (Continued)

SURVEILLANCE REQUIREMENTS 4.4.11.1 Each PORV shall be demonstrated OPERABLE at least once per 18 months by operating the PORV through one complete cycle of full travel.

4.4.11.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by operating the valve through one complete cycle of full travel unless the block valve is closed to meet required ACTIONS a, b, or c.

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BEAVER VALLEY - UNIT 2 INSERT 2 - PAGE 2 i

NPF-73 EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. At least once per 31 days when the RCS pressure is above 1000 psig by verifying that power to the isolation valve operator control circuit is disconnected by removal of the plug in the lock out jack from the circuit.

4.5.1.2 Each accumulator water level and pressure alarm channel shall be demonstrated OPEPABLE:

a. At least once per 31 days by the performance of a CHANNEL FUNCTIONAL TEST.

b. At least once per 18 months by the performance of a CHANNEL

- m cVed YE 3,w YC' b5 ** 4' M

(.5.1.3 During normal plant cooldown and depressurization, each accumulator discharge isolation valve 2 SIS-MOV 865 A, B, and C shall be verified to be closed

and de-energized when RCS pressure is reduced to 1,000 t 100 psig.

m ove ol Yo Sot elf-ira Ea ss 4.'/.93. I.h With the accumulator pressure less than the low temperature overpressure protection setpoint the accumulator discharge isolation valves may be opened to perform accumulator discharg check valve testing.

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BEAVER VALLEY - UNIT 2 3/4 5-2 Amendment No.

PA 0PK&b

NPF-73 REACTOR COOLANT SYSTEM BASES 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

The pressure-temperature limit lines shown on Figure 3.4-2 for reactor criticality and for inservice leak and hydrostatic testing have been provided to assure compliance with the minimum temperature requirements of Appendix G to 10 CFR 50 for reactor criticality and for inservice leak and hydrostatic testing.

The number of reactor vessel irradiation surveillance specimens and the frequencies for removing and testing these specimens are provided in UFSAR Table 5.3-6 to assure compliance with the requirements of Appendix H to 10 CFR Part 50.

The limitations imposed on the pressurizer heatup and cooldown rates and auxiliary spray water temperature differential are provided to assure that the pressurizer is operated within the design criteria assumed for the fatigue analysis performed in accordance with the ASME Code requirements.

Pressure-temperature limit curves shown in figure B 3/4 4-3 were developed for the limiting ferritic steel component within an isolated reactor coolant loop. The limiting component is the steam generator channel head to tubesheet region. This figure provides the ASME III, Appendix G limiting curve which is used to define operational bounds, such that when operating with an isolated loop the analyzed pressure-temperature limits are known. The tonperature range provided bounds the expected operating range for an isolated loop.

he v.TERAoALATY of two PORVs or an RCS vent opening of greater than 3.14 square inches ensures that the RCS will be protected from pressure transients which could exceed the limits of Appendix G to 10 CFR Part 50 when one or more of the RCS cold legs are s 350'F.

Either PORV has adequate relieving capability to protect the RCS from

[ overpressurization when the transient start of an idle RCP with the secondary is limited to either (1) the water temperature of the steam generator $ 50*F above the RCS cold leg temperature or (2) the start of a' charging pump and its injection into a water solid RCS.

ERPRESSURE PROTECTION SYSTEM 3h The Maximpa Allowed PORV Setpoint for the Overpressure Protection i

Systems (OPPS). is derived by analysis which models the performance of the OPPS assuming various mass input and heat input transients.

Operation with a PORV setpoint less than or equal to the maxi.ur setpoint ensures that nominal 10 EPPY Appendix G limits will not ce violated with consideration for: (1) a maximum pressure oversheet beyond the PORV setpoint which can occur as a result of time delays in signal processing and valve opening; (2) a 50*F heat transpcrt effect made possible by the geometrical relationship of the .:HP suction line and the RCS wide range temperature indicator used ::r OPPS; (3) instrument uncertainties; and (4) single failure.

R&#L &cE t.)/T)Y ZAIS EA7" 3 BEAVER VALLEY - UNIT 2 B 3/4 4-14 hkOf0SEb

INSERT 3 OVERPRESSURE PROTECTION SYSTEMS BACKGROUND The overpressure protection system (OPPS) controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G. The reactor vessel is the limiting RCPB component for demonstrating such protection. The maximum setpoint for the power operated relief valves (PORVs) and the maximum RCS pressure for the existing RCS cold leg temperature during cooldown, shutdown, and heatup meet the 10 CFR 50, Appendix G requirements during the OPPS MODES.

The reactor vessel material is less tough at low temperatures than at normal operating temperature. As the vessel neutron exposure accumulates, the material toughness decreases and becomes less resistant to pressure stress at low temperatures. RCS pressure, therefore, is maintained low at low temperatures and is increased only as temperature is increased.

The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only during shutdown; a pressure fluctuation can occur more quickly than an operator can react to relieve the condition. Exceeding the RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel. LCO 3.4.9.1, " Pressure / Temperature Limits," requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the limits.

This LCO provides RCS overpressure protection by having a minimum coolant input capability and having adequate pressure relief capacity. Limiting coolant input capability requires deactivating all but one charging pump 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 device that acts to terminate an increasing pressure event.

With minimum coolant input capability, the ability to provide core coolant addition is restricted. The LCO does not require the makeup control sy_ stem deactivated or the safety injection (SI) actuation circuits blocked. Due to the lower pressures in the OPPS MODES and the expected core decay heat levels, the makeup system can provide adequate flow via the makeup control valve and, if needed, until the charging pump is actuated by SI.

The OPPS for pressure relief consists of two PORVs with reduced lift settings or a depressurized RCS and an RCS vent of sufficient size. Two RCS relief valves are required for redundancy. One RCS relief valve has adequate relieving capability to keep from overpressurization for the required coolant input capability.

BEAVER VALLEY - UNIT 2 INSERT 3 - PAGE 1

YNSERT 3 (Continued)

PORV REQUIREMENTS As designed for the OPPS System, each PORV is signaled to open if the RCS pressure approaches a limit determined by the OPPS actuation logic. The OPPS actuation logic monitors both RCS temperature and RCS pressure and determines when a condition not acceptable in the limits is approached. The wide range RCS temperature indications are auctioneered to select the lowest temperature signal. The lowest temperature signal is processed through a function generator that calculates a pressure limit for that temperature. The calculated pressure limit is then compared with the indicated RCS pressure from a wide range pressure channel. If the indicated pressure meets or exceeds the calculated value, a PORV is signaled to open. Having the setpoints of both valves within the limits ensures that the Appendix G limits will not be exceeded in any analyzed event. When a PORV is opened in an increasing pressure transient, the release of coolant will cause the pressure increase to slow and reverse. As the PORV releases coolant, the RCS pressure decreases until a reset pressure is reached and the valve is signaled to close. The pressure continues to decrease below the reset pressure as the valve closes.

RCS VENT REOUIREMENTS Once the RCS is depressurized, a vent exposed to the containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the relieving requirements of the transient do not exceed the capabilities of the vent. Thus, the vent path must be capable of relieving the flow resulting from the limiting OPPS mass or heat input transient, and maintaining pressure below the P/T limits. The required vent capacity may be provided by one or more vent paths.

For an RCS vent to meet the flow capacity requirement, it may be satisfied by removing a pressurizer safety valve or establishing an opening between the RCS and the containment atmosphere of the required size through any positive means available which cannot be inadvertently defeated. The vent path (s) must be above the level of reactor coolant, so as not to drain the RCS when open.

APPLICABLE SAFETY ANALYSES Safety analyses demonstrate that the reactor vessel is adequately l protected against exceeding the P/T limits when low RCS temperature conditions exist. At the enable temperature and below, overpressure prevention is provided by two OPERABLE RCS relief valves or a depressurized RCS and a sufficient sized RCS vent.

i BEAVER VALLEY - UNIT 2 INSERT 3 - PAGE 2

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l INSERT 3 (Cpntinued)

APPLICABLE SAFETY ANALYSES (Continued)

The actual temperature at which the pressure in the P/T limit curve falls below the OPPS setpoint increases as the reactor vessel material toughness decreases.due to neutron embrittlement. Each time the heatup and cooldown curves are revised, the OPPS must be re-evaluated to ensure its functional requirements can still be met.

The heatup and cooldown curves represent the Appendix G limits that define OPPS operation. Any change to the RCS that may affect OPPS operation must be evaluated against the analyses to determine the impact of the change on the OPPS acceptance limits.

Transients that are capable of overpressurizing the RCS are.

categorized as either mass or heat input transients, examples of which follow:

MASS INPUT TYPE TRANSIENTS

a. Inadvertent safety injection; or

b. Charging / letdown flow mismatch.

HEAT INPUT TYPE TRANSIENTS

a. Inadvertent actuation of pressurizer heaters;

b. Loss of RHR cooling; or

c. Reactor coolant pump (RCP) startup with temperature asymmetry within the RCS or between the RCS and steam generators.

The following are required during the OPPS MODES to ensure that mass and heat input transients do not occur, which either of the OPPS overpressure protection means cannot handle:

1

a. Deactivating all but one charging pump OPERABLE;

b. Deactivating the accumulator discharge isolation valves in their closed positions; and

c. Di'sallowing start of an RCP if secondary temperature is more than 50*F above primary temperature in any one loop. LCO 3.4.1.6, " Reactor Coolant Pump Startup," provides this '

protection.

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BEAVER VALLEY - UNIT 2 INSERT 3 - PAGE 3

INSERT 3 (Continued)

HEAT INPUT TYPE TRANSIENTS (Continued)

The analyses demonstrate that either one RCS relief valve or the depressurized RCS and RCS vent can maintain the RCS pressure below the limits when only one charging pump is actuated by SI. Thus, the LCO allows only one charging pump OPERABLE during the OPPS MODES.

Since neither one RCS relief valve nor the RCS vent can handle a full SI actuation, the LCO also requires the accumulators isolated.

The isolated accumulators must have their discharge valves closed with power removed. Fracture mechanics analyses established the temperature of OPPS Applicability at the enable temperature.

PORV PERFORMANCE The fracture mechanics analyses show that the vessel is protected when the PORVs are set to open at or below the limit. The setpoint ,

is derived by analyses that model the performance of the OPPS assuming the limiting transient of SI actuation of one charging pump. These analyses consider pressure overshoot and undershoot beyond the PORV opening and closing, result (ng from signal processing and valve stroke times. The PORV setpoints at or below the derived limit ensures the P/T limits will be met.

The Maximum Allowed PORV Setpoint for the OPPS is derived by analysis which models the performance of the OPPS assuming various mass input and heat input transients. Operation with a PORV setpoint less than or equal to the maximum setpoint ensures that Appendix G limits will not be violated with consideration for: (1) a maximum pressure overshoot beyond the PORV setpoint which can occur as a result of time delays in signal processing and valve opening; (2) a 50*F heat transport effect made possible by the geometrical 4 relationship of the RHR suction line and the RCS wide range i temperature indicator used for OPPS; (3) instrument uncertainties; ;

and (4) single failure.

l The PORV setpoint will be updated when the revised P/T limits conflict with the OPPS analysis limits. The P/T limits sre periodically modified as the reactor vessel material toughness 3 decreases due to neutron embrittlement caused by neutron i irradiation. Revised limits are determined using neutron fluence I projections and the results of examinations of the reactor vessel ;

material irradiation surveillance specimens. The Bases for LCO j 3.4.9.1, " Pressure / Temperature Limits," discuss these examinations. l The PORVs are considered active components. Thus, the failure of one PORV is assumed to represent the worst case, single active failure.

i BEAVER VALLEY - UNIT 2 INSERT 3 - PAGE 4

INSERT 3 (Continued)

RCS VENT PERFORMANCE With the RCS depressurized, analyses show that a PORV or equivalent opening with a vent size of 3.14 square inches is capable of mitigating the allowed OPPS overpressure transient. The capacity of a vent this size is greater than the flow of the limiting transient for the OPPS configuration, SI actuation with one charging pump OPERABLE, maintaining RCS pressure less than the maximum pressure on the P/T limit curve.

The RCS vent size is based on the PORV size, therefore, the vent is bounded by the PORV analyses.

The RCS vent is passive and is not subject to active failure.

LCD This LCO requires that the OPPS is OPERABLE. The OPPS is OPERABLE when the minimum coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the limits as a result of an operational transien't.

To limit the coolant input capability, the LCO requires one charging pump capable of injecting into the RCS and all accumulator discharge isolation valves closed and immobilized. The LCO is qualified by a note that permits two pumps capable of RCS injection for less than or equal to 15 minutes to allow for pump swaps. This note also allows all charging pumps capable of injecting into the RCS during a change from MODE 3 to MODE 4 to be OPERABLE for a limited period of time.

The LCO is also qualified by a note stating that accumulator isolation with power removed from the discharge isolation valves is only required when the accumulator pressure is greater than or at the maximum RCS pressure for the existing temperature, as allowed by the P/T limit curves. This note permits the accumulator discharge isolation valve surveillance to be performed only under these pressure and temperature conditions.

Operation' above 350*F but less than 375'F with only one centrifugal charging pump OPERABLE is allowed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . As shown by analysis, LOCAs occurring at low temperature, low pressure conditions can be successfully mitigated by the operation of a single centrifugal charging pump and a single LHSI pump with no credit for accumulator injection. Given the short time duration that the condition of having only one centrifugal charging pump OPERABLE is allowed and the probability of a LCCA occurring during this time, the failure of the single centrifugal charging pump is not assumed.

BEAVER VALLEY - UNIT 2 INSERT 3 - PAGE 5

l INSERT 3 (Continued) j l

l LCO (Continued)

Operation below 350*F but greater than 325*F with all centrifugal charging pumps OPERABLE is allowed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months immediately following a change from Mode 3 to Mode 4. This provides a reasonable period of time for the operators to secure an OPERABLE pump following entry into MODE 4. Since the charging pump is required to be OPERABLE in MODE 3 but is not required in MODE 4 due to OPPS limitations, some time constraints for making the transition must be identified. During low pressure, low temperature operation, all automatic Safety Injection actuation signals are blocked. In normal conditions, a single failure of the ESF actuation circuitry will result in the starting of at most one train of Safety Injection (one centrifugal charging pump, and one LHSI pump). For temperatures above 325'F, an overpressure event occurring as a result of starting these two pumps can be successfully mitigated by operation of both PORVs without exceeding Appendix G limits. Given the short time duration that this condition is allowed and the low probability of a single failure causing an overpressure event during this time, the single failure of a PORV is not assumed. Initiation of both trains of Safety Injection during this 4-hour time frame due to operator error or a single failure occurring during testing of a redundant channel are not considered to be credible accidents.

The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

a. Two OPERABLE PORVs; a PORV is OPERABLE for OPPS when its block valve is open, its lift setpoint is set to the limit and testing proves its ability to open at this setpoint, and motive power is available to the two valves and their control circuits; or

b. A depressurized RCS and an RCS vent.

An RCS vent is OPERABLE when open with an arca of 3.14 square inches.

Each of these methods of overpressure prevention is capable of mitigating the limiting OPPS transient.

APPLICABILITY This LCO is applicable in MODE 4 when any RCS cold leg temperature is less than or equal to the enable temperature, in MODE 5, and in MODE 6 when the reactor vessel head is on. When the reactor veasel head is off, overpressurization cannot occur.

Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event.

BEAVER VALLEY - UNIT 2 INSERT 3 - PAGE 6

INSERT 3 (Continued)

ACTION

a. With two or more charging pumps capable of injecting into the RCS, RCS overpressurization is possible.

To immediately initiate action to restore restricted coolant input capability to the RCS reflects the urgency of removing the RCS from this condition.

b. An unisolated accumulator requires isolation within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

This is only required when the accumulator pressure is at or more than the maximum RCS pressure for the existing temperature allowed by tha P/T limit curves.

If isolation is needed and cannot be accomplished in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the ACTION provides two options, either of which must be performed in the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . By increasing the RCS temperature to more than the enable temperature, the accumulator pressure cannot exceed the OPPS limits if the accumulators are fully injected. Depressurizing the accumulators below the OPPS '

limit also gives this protection.

l l

The completion times are based on operating experience that these activities can be accomplished in these time periods indicating that an event requiring OPPS is not likely in the allowed times.

c. In MODE 4 when any RCS cold leg temperature is less than or equal to the enable temperature, with one required RCS

relief valve inoperable, the RCS relief valve- must be restored to OPERABLE status within a completion time of 7 days. Two RCS relief valves are required to provide low temperature overpressure mitigation while withstanding a single failure of an active component. The exception to specification 3.0.4 will permit plant heatup with one inoperable PORV. Continued operation is permitted with one PORV inoperable.

The completion time considers the facts that only one of the RCS relief valves is required to mitigate an overpressure transient and that the likelihood of an active failure of the remaining valve path during this time period is very '

low. If plant operation results in transitioning to MODE 5, l the completion time to restore an inoperable PORV may not exceed 7 days as required by this ACTION.

d. The consequences of_ operational events that will l

overpressurize the RCS are more severc' at lower temperature. Thus, with one of the two RCS relief valves l

inoperable in MODE 5 or in MODE 6 with the head on, the completion time to restore two valves to OPERABLE status is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

BEAVER VALLEY - UNIT 2 INSERT 3 - PAGE 7 l

i

INSERT 3 (Continued)

ACTION (Continued)

The completion time represents a reasonable time to investigate and repair several types of relief valve failures without exposure to a lengthy period with only one OPERABLE RCS relief valve to protect against overpressure events. If a PORV is inoperable when the plant enters MODE 5 from MODE 4, the completion time to restore an inoperable PORV changes to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months but the cumulative inoperable time may not exceed 7 days before taking action to depressurize and vent.

e. The RCS must be depressurized and a vent must be established within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when both required'RCS relief valves are inoperable. The vent must be sized greater than or equal to 3.14 square inches to ensure that the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES. This action is needed to protect the RCPB from a low temperature overpressure event and a possible brittle failure of the reactor vessel. ,

The completion time considers the. time required to place the plant in this condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements.

SURVEILLANCE REQUIREMENTS (SR)

ER 4.4.9.3 1 To minimize the potential for a low temperature overpressure event by limiting the mass input capability, a maximum of one charging pump is OPERABLE with the others verified deactivated with power removed and the accumulator discharge isolation valves are verified closed and locked out.

The frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering other indications and alarms available to the operator in the control room, to verify the required status of the equipment.

SR 4.4.9.3.1.b allows opening the accumulator discharge isolation valves to perform accumulator discharge check valve testing.

SR 4.4.9.3.2 The PORV block valve must be verified open every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to provide the flow path for each required PORV to perform its function when actuated. The valve must be remotely verified open in the main control room. This surveillance is performed if the PORV satisfies the LCO.

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DEAVER VALLEY - UNIT 2 INSERT 3 - PAGE 8

l l

, INSERT 3 (Continued)

SURVEILLANCE REQUIREMENTS (SR) (Continued)

The block valve is a remotely controlled, motor operated valve.

The power to the valve operator is not required removed, and the manual operator is not required locked in the inactive position.

Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months frequency is considered adequate in view of other administrative controls available to the operator in the control room, such as valve position indication, that verify that the PORV block valve remains open.

The SR is required to be performed prior to entering the condition for the OPPS to be OPERABLE. This assures low temperature overpressure protection is available when the RCS cold leg temperature is less than or equal to the enable temperature.

Performing the surveillance every 31 days on each required PORV permits verification and adjustment, if necessary, of its lift setpoint, and considers instrumentation reliability which has been-shown through operating experience to be acceptable. The CHANNEL FUNCTIONAL TEST will verify the setpoint is within the allowed maximum limits. PORV actuation could depressurize the RCS and is not required.

Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 months to1 adjust the whole channel so that it responds and the valve opens within'the required range and accuracy to known input.

SR 4.4.9.3.3 The RCS vent of greater than or equal to 3.14 square inches is proven OPERABLE by verifying its open condition either:

a. Once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for an open vent or valve that cannot be locked, except

b. Once every 31 days for a valve that is locked, or'provided with remote position indication, or sealed, or secured in position. A removed pressurizer safety valve fits this category.

The passive vent arrangement must only be open to be OPERABLE.

This surveillance is required to be perforr.ed if the vent is being used to satisfy the pressure relief requirements of the LCO.

l BEAVER VALLEY - UNIT 2 INSERT 3 - PAGE 9 w rdr -'

-e + - + - g y e w w av - --

rWw

NPF-73 EEACTOR COOLANT SYSTEM BASES OVERPRSSURE PROTECTION SYSTEMS (Continued)

To ensure mass and heat input transients more severe than those %

assumed cannot occur, Technical Specifications require lockout of all but one centrifugal charging pump while in MODES 4, 5, and 6 with the reactor vessel head installed and disallow start of an RCP if secondary coolant temperature is more than 50'F above reactor coolant temperature. Exceptions to these requirements are acceptable as described below.

Operation above 350*F but less than 375'F with only one centrifugal charging pump OPERABLE is allowed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . As shown by analysis LOCAs occurring at low temperature, low pressure conditions can be successfully mitigated by the operation- of a single centrifugal charging pump and a single LHSI pump with no credit for accumulator injection. Given the short time duration that the condition of having only one centrifugal charging pump OPERABLE is allowed and the probability of a LOCA occurring during this time, the failure of the single centrifugal charging pump is not assumed.

Operation below 350*F but greater than 325'F with all centrifugal charging pumps OPERABLE ja allowed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . During low pressure, low temperature operation all automatic Safety Injection actuation signals are blocked. In normal conditions a single failure of the ESF actuation circuitry will result in the starting of at most one train of Safety Injection (one centrifugal charging pump, and one LHSI pump). For temperatures above 325'F, an overpressure event occurring as a result of starting these two pumps can be successfully mitigated by operation of both PORVs without exceeding Appendix G limit.

and the Given the short time duration that this condition is allowed low probability of a single failure causing an overpressure event during this time, the single failure of a PORV is not assumed.

Initiation of both trains of Safety Injection during this 4-hour time frame due to operator error or a single failure occurring during testing of a redundant channel are not considered to be credible accidents.

The maximum allowed PORV setpoint for the overpressure Protection System will be updated based on tho' results of examinations of reactor vessel. material irradiation surveillance specimens performed i

as required by 10 CFR Part 50, Appendix H and in accordance with the

_ schedule in UFSAR Table 5.3-6.

3/4.4.10 STRUCTURAL INTEGRITY t IMbb I 3 C The inservice inspection and testing programs for ASME Code Class 1, 2 and 3 components ensure that the structural integrity and operational readiness of these components will be maintained at an acceptable level throughout the life of the plant. These progra.s are in accordance with Section XI of the ASME Boiler and Pressure vessel Code and applicable Addenda as required by 10 CFR Par:

50.55a(g) except where specific written relief has been granted

/

! the Commission pursuant to 10 CFR Part 50.55a (g) (6) (i) .

BEAVER VALLEY - UNIT 2 B 3/4 4-15 N O h0SW

NPF-73 ;

I REACTOR COOLANT SYSTEM l

l BAsrs 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES .7~N I W Y L The relief valves have remotely operated block valves to provide a positivh

' shutoff capability should a relief valve become inoperable. The electrical-power for both the relief valves and the block valves is supplied from an emer-gency power source to ensure the ability to seal this possible RCS leakage path, The operability of at least one PORV will ensure the additional capability to QentthepressurizerstaanspaceviathePORV's.

3/4.3.12 RD CTOR COOLANT SYSTEM HGO VENTS Reactor Coolant Systaa Vents are provided to exhaust noncondensible gases and/or steam from the primary system that could inhibit natural circulation cure cooling. The OPERASILIW of at least one reactor coolant systen vent path from the reactor vessel head or the pressurizer steam space via the PORV's i ensures the capability exists to perfore this function. '

The valve n i n j of the Reactor Coolant Systen Head vent paths serves to einfeize ths probability of inadvertent or irreversible actuation while ensuring that a single failure of a vent valve, power supply or control'systes does not prevent isolation of the vent path.

The function, capabilities, and testing requirements of the Reactor Coolant Systen vent systems are consistent with the requirements of Iten II.B.1 of '

NUREG-0737, " Clarification of TMI Action Plan Requirements", November 1980.

ev .

'?

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BEAVER VALLEY - UNIT 2 8 3/4 4-16 Pf08030

l INSERT 4 1

BACKGROUND i The Pressurizer is equipped with two types of devices for l pressure relief: pressurizer safety valves and PORVs. The PORVs are l electro-solenoid actuated valves that are controlled to open in l response to a signal from a pressure sensing system when the l pressurizer pressure increases and close when the pressurizer !

pressure decreases. The PORVs way also be manually operated from the control rocm.

Block valves, which are normally open, are located between the pressurizer and the PORVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room.

A stuck open PORV is, in effect, a small break loss of coolant accident (LOCA). As such, block valve closure terminates the RCS depressurization and coolant inventory loss.

The PORVs and their associated block valves may be used by plant operators to depressurize the RCS to recover from certain transients if normal pressurizer spray is not avalJable. Additionally,-the series arrangement of the PORVs and their block valves permit performance of certain surveillances on the valves during power operation.

The PORVs may also be used for feed and bleed core cooling in the case of multiple equipment failure events that are not within the design basis, such as a total loss of feedwater.

The PORVs, their block valves, and their controls are powered from emergency power sources in the event of a loss of offsite power. Two PORVs and their associated block valves are powered from two separate safety trains.

The plant has three PORVs, each having a relief capacity of 210,000 lb/hr at 2350 psig. The functional design of the PORVs is based on maintaining pressure below the high pressure reactor trip setpoint. In addition, the PORVs minimize challenges to the pressurizer safety valves and also may be used for low temperature overpressure protection (OPPS). See LCO 3.4.9.3, " Overpressure Protection System." ,

1 APPLICABLE SAFETY ANALYSES I

Plant operators employ the PORVs to depressurize the RCS in response to certain plant transients if normal pressurizer spray is ;

not available. For the Steam Generator Tube Rupture (SGTR) event, i the safety analysis assumes that manual operator actions are required to mitigate the event. A loss of offsite power is assumed to accompany the event, and thus, normal pressurizer spray is l

l BEAVER VALLEY - UNIT 2 INSERT - PAGE 1

INSERT 4 (Continued).

APPLICABLE SAFETY ANALYSES (Continued) unavailable to reduce RCS pressure. The PORVs are assumed to be used for RCS depressurization, which is one of the steps performed to equalize the primary and secondary pressures in order to terminate the primary to secondary break flow and the radioactive releases from the affected steam generator.

The PORVs are used in safety analyses for events that result in increasing RCS prescure for which departure from nucleate boiling ratio (DNBR) criteria are critical. Certain analyses have been performed to study the effects on primary pressure assuming PORV actuation. The results of the turbine trip event indicate the primary pressure remains within the design limits and the DNBR is maintained within the acceptance criteria.

LCQ The LCO requires the PORVs and their associated block valves to be OPERABLE for manual operation to mitigate the effects associated with an SGTR.

By maintaining at least two PORVs and their associated block valves OPERABLE, redundancy has been provided. The block valves are available to isolate the flow path through either a failed open PORV or a PORV with excessive leakage. Satisfying the LCO helps minimize challenges to fission product barriers.

APPLICABILITY In MODES 1, 2, and 3, the PORV and its block valve are required to be OPERABLE to limit the potential for a small break LOCA through the flow path. The most likely cause for a PORV small break LOCA is a result of a pressure increase transient that causes the PORV to open. Imbalances in the energy output of the core and heat removal by the secondary system can cause the RCS pressure to increase to the PORV opening setpoint. The most rapid increases will occur at the higher operating power and pressure conditions of MODES 1 and 2. The PORVs are also required to be OPERABLE in MODES 1, 2, and 3 to minimize challenges to the pressurizer safety valves.

Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. Therefore, the LCO is applicable in MODES 1, 2, and 3. The LCO is not l applicable in MODE 4 when both pressure and core energy are decreased I and the pressure surges become much less significant. The PORV j setpoint is reduced for OPPS in MODES 4 (below the enable i temperature), 5, and 6 with the reactor vessel head in place. LCO !

3.4.9.3 addresses the PORV requirements in these MODES.

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1 BEAVER VALLEY - UNIT 2 INSERT 4 - PAGE 2 I l

j

INSERT 4 (Continued)

ACTION A General Note provides clarification that all pressurizer PORVs and block valves are treated as separate entities, each with separate completion times (i.e., the completion time is on a component basis),

a. With one PORV inoperable, either the PORV must be restored or the flow path isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The block valve should be closed with power removed from the associated block valve because of downstream piping concerns. With the block valve closed, the potential exists to condense steam in the piping between the block valve and the downstream PORV. If the block valve were opened and the PORV actuated, the piping downstream of the PORV may be overstressed due to the slug of water being forced down the piping. Based on the downstream piping concern, it is prudent to remove power from the closed block valve. Removing power from the block valve renders the block valve inoperable, however, two PORVs and their associated block valves remain OPERABLE and redundancy exists for PORV operation. Therefore, plant operation may continue with one block valve closed and power removed. PORV inoperability may be due to seat leakage, instrumentation problems (including' PORV accident monitoring instruments identified in LCO 3.3.3.8), or other causes.

Automatic control problems and related instrumentation probleas would not render the PORVs inoperable. Accident analyses assume manual operation of the PORVs and do not take credit for automatic actuation. This condition is only intended to permit operation of the plant for a limited period of time not to exceed the next refueling outage so that maintenance can be performed on the PORV to return the valve to an OPERABLE condition. Normally, the PORV should be available for automatic mitigation of overpressure events and should be returned to OPERABLE status prior to entering startup (MODE 2).

The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is based on plant operating experience that has shown that minor problems can be corrected or closure accomplished in this time period.

b. With two PORVs inoperable, they must be either restored or isolated by closing the associated block valves and removing the power to the associated block valves. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on challenges to the PORVs during this time period, and provides the operator adequate time to correct the situation. If the inoperable valves cannot be restored to OPERABLE status, the inoperable valves must be isolated within the specified time. Because there is one PORV that remains OPERABLE, an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is provided to restore at least one inoperable PORV to OPERABLE status. If a PORV cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply.

BEAVER VALLEY - UNIT 2 INSERT 4 - PAGE 3

INSERT 4 (Continued)

ACTION (Continued)

c. If three PORVs are inoperable, it is necessary to either restore at least one valve within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or isolate the flow path by closing and removing the power to the associated block valves. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. If one PORV is restored, then the plant will be in a less limiting ACTION statement with the time clock started at the original declaration of .having three PORVs inoperable. If no PORVs are restored within the completion time, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed completion times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, maintaining PORV OPERABILITY may be required. See LCO 3.4.9.3.

d. If one block valve is inoperabl'e and open, then it is necessary to either restore the block valve to OPERABLE status within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or place the associated PORV in manual control. The prime importance for ,

the capability to close the block valve is to isolate a j stuck open PORV. Therefore, if the block valve cannot be '

restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the required i action is to place the PORV in manual contro.1 to preclude j its automatic opening for an overpressure event and to avoid l the potential for a stuck open PORV at a time that the block valve is inoperable. If the block valve is inoperable, it ,

is necessary to restore the block valve to OPERABLE status I within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or close it. If block valve instrumentation l related to accident monitoring instrumentation identified in I LCO 3.3.3.8 is determined to be inoperable, then the block i valve shall be declared inoperable. Closing the block valve i precludes the need to place the PORV in manual control since l it is isolated from the system. The completion time of 1 !

hour is reasonable, based on the small potential for I challenges to the system during this time period, and '

provides the operator time to correct the situation.

Because at least one PORV remains OPERABLE, the operator is permitted a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable open block valve to OPERABLE status. If it cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply in order to avoid continuous operation without a redundant ability to isolate this PORV flow path. If the block valve is restored within the completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the power will be restored and the PORV restored to OPERABLE status. clith one block valve inoperable and closed, there BEAVER VALLEY - UNIT 2 INSERT 4 - PAGE 4

INSERT 4 (Continuedl ACTION (Continued) still remains two PORV flow paths. This redundancy will allow continued operation until the next refueling outage to perform maintenance on the inoperable valve and return it to OPERABLE status,

e. If more than one block valve is inoperable, it is necessary to either restore the block valves within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or place the associated PORVs in manual control and restore at least one block valve within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (and restore a minimum of two block valves within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ). Two OPERABLE PORVs provide redundancy to allow continued operation until the next refueling outage to perform maintenance on the inoperable valve and return it to OPERABLE status. The completion times are reasonable, based on the small potential for challenges to the system during this time and provide the operator time to correct the situation. If the required actions are not met, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 at least MODE 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The allowed completion ti'mes are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, maintaining PORV OPERABILITY may be required. See LCO 3.4.9.3.

SURVEILLANCE REOUIREMENTS (SR)

SR 4.4.11.1 This surveillance requires a complete cycle of each PORV.

Operating a PORV through one complete cycle ensures that the PORV can be manually actuated for mitigation of an SGTR. The frequency of 18 months is based on a typical refueling cycle and industry accepted practice. ;

SR 4.4.11.2 Block valve cycling verifies that the valve (s) can be closed if l needed. The basis for the frequency of 92 days is the ASME Code, i Section XI. If the block valves are closed to isolate inoperable l PORVs, the maximum completion time to restore one PORV and open the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , which is well within the allowable limits ;

(25%) to extend the block valve frequency of 92 days. Furthermore, i these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e., completion of the required actions fulfills the SR).

This SR is not required to be met with the block valve closed, in accordance with required ACTIONS a, b, or c of this LCO.

BEAVER VALLEY - UNIT 2 INSERT 4 - PAGE 5

-NPF-73 ADMINISTRATfiE CONTROLS i

l

_SPECIAL REPORTS (Continued)

d. Seismic event analysis, Specification 4.3.3.3.2. t e.

Sealed source leakage in excess of limits, Specification 4.7.9.1.3.

l

f. Miscellaneous reporting requirements specified in the State-monts for Radiological Effluent Technical Specifications.

g.

Containment Inspection Report, Specification 4.6.1.6.2.

h.

Steam generator tube inservice inspection, Specifiestion 4.4.5.5.

i. Inoperable accident monitoring, Specification 3.3.3.8.

j. W etica ef "00!; ;r RCS n at;, S w ificeti;a 0.4.0.0. I 6.10 RECORD RETENTION 6.10.1 The following records shall be retained for at least five (5) years; l a.

Recorde and logs of facility operation covering time interval at each power level.

b.

Records repair andand replogs of principal maintenance activities, inspections, nucieer safety. scament of principal itses of equipment related to Lu cart - '

c. h NWEM.

d. i Records-of surveillance activities, inspections and calibrations i required by these Technical Specifications.

l

e. Records of reacter tests and experiments. I

f. Records of, cimages made to Operating Procedures,

g. h rts-of radienctive shipments.

j

h. , M of seeled source leak tests and results.

i. ReIerds of annual physical . inventory of all sealed source material of record. 1 t

6.10.2 )

The following Facility Operating records shall be retained for the duration of the L'conse:

a.

Records and drawing changes reflecting facility design modifications made Report.to systans and equipment described in the Final Safety Analysis BEAVER VALLEY - UNIT 2

%.6-19f03ED v - - ~ e

ATTACHMENT B l l

Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 REVISION OF PORV REQUIREMENTS l

l l

A. DESCRIPTION OF AMENDMENT REQUEST i The proposed amendment would modify Specifications 3.4.9.3 and 3.4.11 to incorporate the power operated relief valve (PORV) requirements in accordance with the guidance in Generic Letter 90-06 as implemented in NUREG-1431 Improved Standard Technical Specifications (ISTS), with some exceptions and modifications to reflect plant specific design features. Certain other specifications have also been modified to address related ,

requirements. A detailed description of the changes is provided in Attachment D.

B. BACKGROUND Generic Letter 90-06 was issued to recommend appropriate PORV technical specifications to licensees to enhance plant safety and improve the reliability of the PORVs. Our response, dated December 26, 1990, to the generic letter included various changes to the technical specifications which were provided as information for discussion since some deviation to the generic letter was necessary. On July 1, 1991, a revised schedule for submitting a request for changing the technical specifications was docketed as a result of negotiating a review approach with our NRC Project Manager. The NRC provided additional guidance in Information Notice 89-32 Supplement 1 " Surveillance Testing of Low-Temperature Overpressure Protection Systems" and the ISTS for Westinghouse plants in NUREG-1431. These regulatory documents have been reviewed and the most current guidance has been generally incorporated into this request for technical specification change.

C. JUSTIFICATION Specification 3.1.2.3 has been modified by adding "At least" to the beginning of the limiting condition for operation (LCO) and adding note (1) applicable to charging pump. "At least" was added consistent with the need to perform pump testing in accordance with the

note. This note is no longer required since the new SR 4.4.9.3.1.a does not preclude performing the testing addressed in the note. Note (1) was added to refer the operator to Specification 3.4.9.3 which contains limitations on the number of charging pumps operable in Modes 4, 5, and 6. The capital letters of " Low Head Safety Injection Pump" have been replaced throughout this specification with lower case letters since the capital letters are inconsistent with other pump titles. The word " charging" has been deleted from the BV-1 i action statement so that the action can be applied to both pumps addressed in the LCO like the BV-2 action statement. The ** note has been deleted since the content of this note is addressed in l

B-1 )

l

e ATTACHMENT B, continued Proposed Technical Specification Change Nos. 184 and 49 i Page 2 Surveillance Requirement (SR) 4.4.9.3.3. Reference to the **

note in SR 4.1.2.3.3.d has been replaced with reference to the vent surveillance requirements in SR 4.4.9.3.3.

SR 4.1.2.3.2 has been deleted from Specification 3.1.2.3 since this requirement has been moved to the LCO of Specification 3.4.9.3 in accordance with the ISTS. The

note has been deleted from Specification 3.1.2.3 since this requirement no longer needs to be addressed due to the change in SR 4.4.9.3.1.a. SR 4.1.2.3.3 has been renumbered to 4.1.2.3.2 to address the deletion of SR 4.1.2.3.2.

Specification 3.3.3.8 actions "a" and "b" have been modified (as appropriate for each unit) to require following the actions of Specification 3.4.11 when PORV position indication and limit switch position indicators are inoperable. This clearly applies the action requirements of Specification 3.4.11 to avoid potential operator confusion. BV-1 Table 4.3-7 has been modified by deleting Item 9 "PORV Control Pressure Channels (PT-RC-444, 445)." This item is not required since the accident analyses assume manual PORV actuation and does not take credit for PORV automatic actuation in Modes 1, 2, and 3.

Specification 3.4.9.3 has been revised to address the ISTS guidance. The LCO includes a requirement to limit to one the number of charging pumps capable of injecting into the RCS (from current SR 4.1.2.3.2) and another requirement to isolate the accumulators (from current SR 4.5.1.3). The .ISTS note in Specification 3.4.12 Required Action B.1 has been incorporated as Note (1) and is applied to "one charging pump" in the LCO to qualify the operable charging pump limitations. This note allows two operable charging pumps for a short duration (up to 15 minutes) to swap pumps. This satisfies the requirements of Specifications 3.1.2.1 and 3.1.2.3 when at least.one charging pump is required operable in Modes 5 and 6 and the operable pump is being replaced with another operable pump. The BV-2 Note (1) provides an additional qualifier from the guidance from the current SR 4.1.2.3.2 which permits a maximum of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , or until the RCS temperature decreases to 325'F, to remove one of two charging pumps from operable status. This permits the operators a reasonable amount of time to secure one operable-charging pump following a mode change which happens to coincide with the OPPS enable temperature. The ISTS note referring to accumulator isolation has been identified as Note (2) and is applied to

" accumulators isolated" in the LCO. Items "a" and "b" have been modified to incorporate the ISTS wording while maintaining the current limits. The applicability statement also includes the new wording along with incorporating the current overpressure protection system (OPPS) enable temperature. The action statements provide alternative steps to follow when the LCO is not met and are consistent with the ISTS except that the current 12 hour time to vent the RCS is maintained. The current 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B-2

ATTACHMENT B, continued Proposed Technical Specification Change Nos. 184 and 49 Page 3 time to vent the RCS was negotiated with the NRC during the initial development of Specification 3.4.9.3 since the.8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months recommended in the Standard Technical Specifications was insufficient to perform all the necessary activities to vent the l RCS. SR 4.4.9.3.2.b is consistent with the current requirements and requires demonstrating the PORV actuation channel is I operational prior to entering a condition for which the PORV is l

, required to be operable. The remaining SRs are consistent with L the ISTS and periodically verify the applicable LCO conditions l

are met and the required equipment is operable.

Specification 3.4.11 has been revised to address the ISTS L guidance. The LCO has been modified to apply to "Each" PORV, l therefore, all PORVs are now addressed. The applicability i remains unchanged. The Action statements provide alternatives l when the LCO is not met and are consistent with the ISTS except for a plant specific change for BV-2 which includes modified actions for inoperable PORVs and the ability to continue to ,

operate (for each unit) with two vent paths operable versus j requiring a plant shutdown after 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The ISTS describes '

two situations where PORVs are inoperable and requires a i determination of whether or not the PORV is or is not capable of I being manually cycled. This concept has not been applied to BV-2 since with a PORV inoperable the block valve must be closed and power removed to prevent subsequent opening which will avert a l potential downstream piping overstress condition. ISTS Note 1 l' allows for separate condition entry for each PORV and has been included in this format as a general note. The SRs periodically verify the applicable LCO required equipment is operable and are consistent with the ISTS except for:

SR 4.4.11.1 is consistent with current requirements, and requires operating the PORV through one complete cycle. For Unit 1, this includes using the normal air supply system along with testing the backup nitrogen supply system. This is consistent with Information Notice 89-32 Supplement 1. Testing in this manner assures each component within the PORV control system necessary to support PORV operation has been determined to function satisfactorily. ,

i Unit 1 has deleted SR 4.4.11.3 since the PORVs and block valves i are normally supplied by emergency power sources. This power arrangement has been reviewed and approved as part of the NRC evaluation of NUREG-0737, Item II.G.1.1, which required the PORVs q and block valves to be supplied from emergency sources of power.

This is documented in: l a) Unit 1 submittals " Discussion of Lessons Learned Short Term {

Requirements," dated November 30, 1979 and June 26, 1980.

b) NRC SER on TMI Lessons Learned Category "A" items, dated October 9, 1980.

B-3

= - .. ..

ATTACHMENT B, continued Proposed Technical Specification Change Nos. 184 and 49 Page 4 Unit 2 does not have a SR 4.4.11.3 since the PORVs and block values are normally supplied by emergency power.

Existing SR 4.5.1.3 and related

note have been deleted since accumulator isolation is now addressed in Specification 3.4.9.3 and SR 4.4.9.3.1.a. This is consistent with the ISTS and is applicable for the OPPS and not for the accumulator specification since the OPPS setpoints are all below the applicability for the-accumulator specification.

Bases 3/4.4.9 " Pressure / Temperature Limits" has been revised by replacing that paragraph related to OPPS with the applicable portions of ISTS B 3.4.12. Bases 3/4.4.11 " Relief Valves" has been modified by replacing the current discussion with the applicable portions of ISTS B 3.4.11. These Bases changes significantly improve the quality and content of the subject discussions.

Unit 2 Administrative Control 6.9.2 "Special Reports" item "j" is being deleted since Specification 3.4.9.3 no longer contains this reporting requirement and this section requires reference to a specific specification.

D. SAFETY ANALYSIS The PORV requirements have been consolidated into Specification 3.4.11 for Modes 1, 2 and 3 and into Specification 3.4.9.3 for Modes 4, 5 and 6. This is consistent with the guidance provided in the NUREG-1431 ISTS with some exceptions to reflect plant specific design features. A detailed comparison.of the proposed j changes with the ISTS is provided in Attachment E. I 1

Specification 3.1.2.3 has been modified by adding "At least" to the beginning of the limiting condition for operation (LCO) and ;

adding note (1) applicable to charging pump. "At least" was !

added to allow testing pumps to return them to operable status since this is controlled for OPPS concerns. A new Note . (1) was added to refer the operator .to Specification 3.4.9.3 which contains limitations on the number of charging pumps operable in Modes 4, 5, and 6. The capital letters of " Low Head Safety Injection Pump" have been replaced throughout this. specification with lower case letters since the capital letters are-inconsistent with other pump titles. The word " charging" has-been replaced with "above" in the BV-1 action statement so that the action statement can be applied to both pumps addressed in i the LCO like the BV-2 action statement. The

note has been-deleted. This note is no longer required since the new SR 4.4.9.3.1.a does not preclude testing inoperable. pumps to return them to operable status. The ** note has been deleted. The content of this note is now addressed in the new SR 4.4.9.3.3, therefore, reference to the ** note in SR 4.1.2.3.3.d is replaced with reference to SR 4.4.9.3.3.

B-4

ATTACHMENT B, continued l Proposed Technical Specification Change Nos. 184 and 49 Page 5 SR 4.1.2.3.2 has been transferred to Specification 3.4.9.3. The Specification 3.4.9.3 LCO now states that an operable OPPS includes a maximum-of one charging pump capable of injecting into the RCS. Action "a" is provided to address the condition when this requirement is not met and SR 4.4.9.3.1.a provides for periodic verification that this requirement is met. Therefore, this modification represents no actual change in requirements, they have just been moved to a different specification.

Specification 3.3.3.8 Action "a" for BV-1 has been revised by modifying the reference to the PORV . requirements from Specification 3.4.11.a to 3.4.11 due to the new Specification 3.4.11 action staterants . This is consistent with the BV-2 action statement. In addition, the same exception to. Action "a" (for both units), when PORVs are isolated, has been added to -

Action "b" (Unit 1 only) to reflect the now Specification 3.4.11 action statements. The exception has been modified slightly to clarify the requirements and ensure the actions of Specification 3.4.11 are applied when the PORV position indication and limit switch position indicators are inoperable. As a result of the revisions to the PORV and block valve operability requirements, restrictions on operation with limit switches inoperable will be the same or more restrictive, depending on the unit and component affected. Operating restrictions for the acoustic monitors, Unit 1 only, will not be changed if one channel is inoperable. If two channels are inoperable, then a less restrictive requirement would be in effect. Current Specification 3.3.3.8 action "b" would require the channel to be restored to operable status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or initiate a plant shutdown. The proposed specification would require isolating the vent path by closing the block valve and maintaining power to the block valve. As per proposed Specification 3.4.11 action "a," operation may continue until the next refueling outage, at which time repairs would be completed. This is considered acceptable since the vent path will be isolated and, therefore, not subject to the potential for sticking open if an auto open signal was generated. It would take three instrument' failures (i.e., limit switch on the valve and two acoustic monitor channels on the same valve discharge line), to climinate position indication capability.per vent path per PORV. In the event the vent path would be needed for manual operation following a plant transiente the block valve is still operable to allow venting and the PORV should still have an operable limit switch. Deleting the BV-1 PORV Control Pressure Channels from Table 4.3-7 is consistent with the accident analyses. These channels are only required for automatic PORV actuation. Automatic actuation is not assumed in.the accident analyses, therefore, this item is not applicable to technical specification control.

SR 4.5.1.3 and its related

note have been moved to Specification 3.4.9.3 and SR 4.4.9.3.1.b. The LCO for Specification 3.4.9.3 now states that an operable OPPS includes B-5

. ATTACHMENT B, continued Proposed Technical Specification Change Nos. 184 and 49 Page 6 accumulator isolation. Action "b" is provided to address the condition when this requirement is not met and SR 4.4.9.3.1.b provides for periodic verification that the requirement is met.

Therefore, although the requirements have been moved to a different specification, this modification does not represent any change in actual requirements.

Our response to Generic Letter 90-06 included an information copy of modifications to Specification 3.4.9.3 and Specification 3.4.11 to incorporate the requirements of the generic letter (GL) with some exceptions to reflect plant specific design features.

Although the concerns addressed by the GL are provided for in the ISTS, the wording has been modified to improve the clarity and understanding of the PORV requirements.

The following compares our response to GL 90-06 with the changes proposed here, which for the most part, result from following the guidance of NUREG-1431, ISTS. For Specification 3.4.9.3, the proposed change differs from the GL response in_that-the proposed change includes the charging pump limitation and accumulator isolation along with recognizing that the RCS vent is part of the OPPS. In addition, for BV-1, the lift setting has been revised to reflect the latest amendment; for BV-2, the current requirements are maintained by reference to Figure 3.4-4. The-BV-1 applicability statement includes reference to.the latest amended enable temperature; for BV-2, the current requirements are maintained by reference to the current enable temperature. A new Note (1) has been added'to qualify the operable charging _ pump limitations. This note is identical to the ISTS note which allows two operable charging pumps for a short time to replace the operable pump required by Specifications 3.1.2.1 and 3.1.2.3 with another operable pump and for Unit. 2 only, provide an-additional ' limitation for securing the second operable . pump following a Mode change. This remains'_ consistent 'with the-existing specification. A new Note (2)_has been added to qualify-the accumulator isolation requirements. The accumulators must be isolated only if the accumulator _ pressure is greater..than or equal to the maximum RCS pressure for the existing.RCS cold. leg temperature allowed by the heatup and cooldown curves.- This note follows the intent of the ISTS note but does not reference the P/T limit curves provided in the Pressure / Temperature.. Limits Report (PTLR) like the ISTS note since'we do not have a PTLR.

Action statements "a," "c," "d,"-and "e" provide 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months _to vent-the RCS. This differs from the 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months provided in the ISTS,.

however, the 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is consistent with the current time and11s' needed to perform all the necessary actions . required to adequately vent the RCS. ' Proposed action statements "a"-and "b" are new and have been added to address two or more charging pumps capable- of injecting into the RCS and accumulator isolation, respectively. Proposed action statements "c" and "d" are.similar to actions "a"' and "b," respectively, in the GL response which address one inoperable PORV. Action statement "c" includes a B - _ - .- . _ . _ _ _ , .

.~4 ATTACHMENT B, continued Proposed Technical Specification Change Nos. 184 and 49 Page 7 qualifier to clearly apply this action in Mode 4 when any RCS cold leg temperature is less than or equal to the enable temperature. This is consistent with the applicability statement and will, reduce the potential for confusion when applying this action. The exception to Specification 3.0.4 has been entirely deleted from the Unit 1 action statements and applied to the Unit 2 action "c" only. By including this provision in action "c,"

the plant would be able to continue with a plant startup provided that it could be accomplished before the action time would expire for restoring the one inoperable PORV to operable' status.

Operating with one inoperable PORV is permitted above Mode 4, therefore, by continuing to heatup the RCS, the plant is placed in a mode for which action "c" does not apply. Proposed action "e" is similar to action "c" provided in the GL response and addresses two inoperable PORVs. Action "d" in the GL response is similar to proposed SR 4.4.9.3.3. Action "e" in the GL response is not addressed in the proposed action statements since the ISTS does not include a requirement to submit a special report when the PORVs or an RCS vent is used to mitigate an RCS pressure transient. Proposed SR 4.4.9.3.1 provides new requirements that were not addressed in the GL response. These new requirements require verification at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that the charging pump limitations and the accumulator isolation requirements are met. Proposed SR 4.4.9.3.2 is similar to those requirements ;

addressed in the GL response with a modification to perform the I channel functional test within 31 days prior to going below the enable temperature. Proposed SR 4.4.9.3.3 requires verification of the RCS vent when used; this is similar to action statement ,

"d" provided in the GL response. )

The response to the GL included adding BV-1 item "i" to 1 Specification 6.9.2 for special reports when the PORVs or an RCS vent is used to mitigate an RCS pressure transient, however, the l ISTS does not include a requirement to submit a special report I l

for this event. In addition, for BV-2 this item (Specification 6.9.2 item "j") is being deleted for the same reason stated I above.

For Specification 3.4.11, the preci~ed change differs from the GL l response in that the proposed 2.c0 change specifies "Each,"

consistent with the ISTS, while the GL response specifies "All" PORVs. The proposed applicability statement is consistent with our response to GL 90-06 and remains applicable in Modes 1, 2Jand

3. The ISTS includes Note 1 which allows separate condition entry for.each PORV. This note has been included in our proposed change as a general note. As discussed in the bases, the note has been added to clarify the intent that all pressurizer PORVs and block valves are treated as separate entities, each with separate completion times since the completion times are on a component basis.

The ISTS action statements address PORVs from the standpoint of

" capable of being manually cycled" whereas the GL response B-7

ATTACHMENT B, continued Proposed Technical Specification Change Nos. 184 and 49 Page 8 addresses the PORVs with respect to " excessive seat leakage."

BV-1 ' proposed action "a" is similar to that in the GL response and the ISTS concerning one or more inoperable PORVs-capable of being manually cycled. However, the actions have been modified slightly to recognize that although there' are three PORVs installed in the plant, two are required to provide the redundancy required for continued plant operation. Proposed actions "b" and "c" apply when inoperable PORVs are not capable of being manually cycled and are similar to our GL response.

However, BV-1 action "b" and BV-2 action "a" include a clarification statement that allows continued plant operation with one PORV isolated until the next refueling outage. This is reasonable since two PORVs remain operable to provide redundancy until the plant can shutdown and perform maintenance to restore the valve to operable status. BV-2 actions "a," "b," and "c" differ from the ISTS actions because they do not address inoperable PORVs from the standpoint of " capable of- being manually cycled" since with the block valves closed the PORV is inoperable. With the block valve closed, the potential would exist to condense steam in the downstream piping. If the block valves were opened and the PORV actuated, the piping could be overstressed due to the slug of water being forced down the piping. Therefore, the actions have been developed to apply with one, two, and three inoperable PORVs and require closing and removing power from the associated block valve. With one PORV inoperable, it is prudent to remove power from the closed block valve to provide additional assurance that the block valve will not be opened to avert the possibility of overstressing the downstream piping. This renders the PORV and block valve inoperable and allows continued operation for the remainder of the- cycle with one closed block valve, however, two operable PORVs and their associated block valves are available to provide redundancy. The actions have been modified slightly to recognize that although there are three PORVs installed in the plant, two are necessary to provide redundancy for continued plant operation. This is more conservative than the current requirements and is consistent with the design of'the plant.

Action "d" is new and addresses one open inoperable block valve; this is different from the GL response but is similar to the ISTS. A clarification statement is included with this action to address an inoperable block valve that may be closed. It requires restoring the inoperable block valve to operable status or closing it within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Continued plant operation is allowed until the next refueling outage since two PORV pressure relief valves remain operable to provide redundancy until.the-plant can shutdown and perform maintenance to restore the valve to operable status. Action "e" addresses more than one inoperable block valve and is similar to the GL response and the ISTS. Reference to Specification 4.0.5 has. been deleted to maintain consistency with the ISTS. SR 4.4.11.1 also requires cycling the PORVs. This is consistent with the ISTS and our GL 90-06 response. In addition, for BV-1 only, this SR requires B-8

l l

ATTACHMENT B, continued )

Proposed Technical Specification Change Nos. 184 and 49 Page 9 cycling the PORVs using the normal air supply system and the l backup nitrogen supply system. This is specified to address the concerns identified in NRC Information Notice 89-32, Supplement 1 with respect to lack of adequate testing when in the OPPS modes.

Testing in this manner assures each component within the PORV control system necessary to support PORV operation has been determined to function satisfactorily. The current SR and the ISTS for OPPS exclude PORV valve operation, therefore, this surveillance is stated here similar to our GL 90-06 response.

The BV-2 PORVs are electro-solenoid actuated valves not subject to the concerns identified in the information notice. This valve design is different from the BV-1 PORV design, therefore, the BV-2 SR only addresses cycling the PORVs. SR 4.4.11.2 requires stroking the block valves quarterly unless the valve is closed in accordance with the required actions. This is consistent with the ISTS and our response to GL 90-06. The existing SR 4.4.11.3 requires stroking the PORVs using the emergency power supply and was only applicable to BV-1 since the existing SR would have this surveillance performed. BV-2 was licensed without requiring this surveillance as a result of different criteria existing at the time of licensing. This SR has been deleted from the BV-1 specification since the PORVs and block valves are normally supplied by emergency power sources and is now consistent with BV-2. This is also consistent with the ISTS.

The bases for Specifications 3.4.9.3 and 3.4.11 have been extensively revised to incorporate the ISTS descriptions with some modifications to address plant specific design requirements. The differences between the ISTS bases and these proposed bases are included in Attachment F.

These changes remain consistent with the analysis assumptions and the operation of the PORVs in accordance with the UFSAR. The requirements of GL 90-06 are substantially addressed in the ISTS which have been incorporated here except for specific design differences. Therefore, these changes have been determined to 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 quo'ed 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 not:

B-9

1 ATTACHMENT B, continued Proposed Technical Specification Change Nos. 184 and 49 Page 10 (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.

The following evaluation is provided for the no significant hazards consideration standards.

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

The proposed changes consolidate the power operated relief valve requirements into Specifications 3.4.9.3 and 3.4.11 which generally adopt the new Improved Standard Technical Specifications of NUREG-1431 to address the concerns identified in Generic Letter 90-06 except for those changes required to reflect plant specific design features. These changes are proposed to enhance safety and improve the reliability of the PORVs and block valves. Since the proposed changes augment or preserve the requirements contained in the current technical specifications, we have concluded that these changes do not involve a significant increase in the probability or consequences of an accident previously evaluated in the UFSAR.

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

The proposed changes do not involve any physical changes to 3 the PORVs or their setpoints. These changes do not delete '

any function previously provided by the PORVs nor has the probability of inadvertent opening been increased.

Accordingly, no new failure modes have been defined for any plant system or component important tx) safety nor has any new limiting single failure been identified as a result of these changes. Therefore, these changes will not create the possibility of a new or different kind of accident from any accident previously evaluated in the UFSAR.

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

The proposed changes have been incorporated to enhance safety and improve the reliability of the PORVs and block valves to ensure their availability when called upon to perform their function. These changes do not affect the manner by which the facility is operated or involve a change to equipment or features which affect the operational characteristics of the facility. Therefore, operation of B-10 i e

ATTACHMENT B, continued Proposed Technical Specification Change Nos. 184 and 49 Page 11 the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safoty.

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.

G. UFSAR CHANGES None.

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B-11

l ATTACHMENT C-1 i Beaver Valley Power Station, Unit No. 1 Proposed Technical Specification Change No. 184 TYPED PAGES i

l Applicable Typed Pages i

I h

e

ATTACHMENT TO LICENSE AMENDMENT No.

FACILITY OPERATING LICENSE NO. DPR-66' DOCKET NO. 50-334 Replace the following pages of Appendix A, Technical Specifications,-

with the enclosed pages as indicated. The revised pages- are

' identified by amendment number and contain vertical lines indicating' the areas of change.

Remove Insert 3/4 1-11 3/4 1-11 3/4 3-50 3/4 3-50 3/4 3-52 3/4 3-52 3/4 4-27a 3/4 4-27a 3/4 4-27b 3/4 4-27b 3/4 4-27c 3/4 4-29 3/4 4-29 3/4 4-29a 3/4 5-2 3/4 5-2 B 3/4 4-10 B 3/4 4-30 B 3/4 4~10a B 3/4 4-10b '

B 3/4 4-10c B 3/4 4-10d B 3/4 4-10e B 3/4 4-10f B.3/4 4-10g B 3/4 4-10h B 3/4 4-101 B 3/4 4-11 B 3/4'4-11 B 3/4 4-11a -

B 3/4 4-11b l B 3/4 4-11c ;

B 3/4 4-11d B 3/4 4-11e B 3/4 4-11f i

~

)

(Proposed Wording) we - r -

DPR-66 REACTIVITY CONTROL SYSTEMS CHARGING PUMP - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.3 At least one charging pump (1) in the boron injection flow path required by Specification 3.1.2.1 or low head safety injection pump (with an open reactor coolant system vent of greater than or equal to 3.14 square inches) shall be OPERABLE and capable of being powered from an OPERABLE bus.

APPLICABILITY: MODES 5 and 6.

ACTION:

With none of the above pumps OPERABLE, suspend all operations l involving CORE ALTERATIONS or positive reactivity changes until one charging pump or low head safety injection pump is restored to l OPERABLE status.

SURVEILLANCE REQUIREMENTS .

4.1.2.3.1 The above required charging pump shall be demonstrated OPERABLE by verifying, on recirculation flow, that the pump develops a discharge pressure greater than or equal to 2402 psig when tested pursuant to Specification 4.0.5.

4.1.2.3.2 When the low head safety injection pump is used in lieu of a charging pump, the low head safety injection pump shall be demonstrated OPERABLE by:

a. Verification of an operable RWST pursuant to 4.1.2.7,

b. Verification of an operable low head safety injection pump l pursuant to Specification 4.5.2.b.2,

c. Verification of an operable low head safety injection flow I path from the RWST to the Reactor Coolant System once per shift, and

d. Verification that the vent is open in accordance with 4.4.9.3.3.

l (1) With two charging pumps OPERABLE, follow Specification 3.4.9.3. !

l l

I BEAVER VALLEY - UNIT 1 3/4 1-11 Amendment No.

(Proposed Wording) ;

I

__--_- - i

DPR-66 INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.8 The accident monitoring instrumentation channels shown in Table 3.3.11 shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

a. With the number of OPERABLE accident monitoring instrumentation channels less than the Total Number of Channels shown in Table 3.3.11, either restore the inoperable channel (s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (follow Specification 3.4.11 when determining ACTIONS for Items 4, 5, and 6).

, b. With the number of OPERABLE accident monitoring instrumentation channels less tha'n the MINIMUM CHANNELS OPERABLE requirements of Table 3.3.11, either restore the inoperable channel (s) to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (follow Specification 3.4.11 when determining ACTIONS for Item 4).

c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.8 Each accident monitoring instrumentation channel shall l be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies shown in Table 4.3-7.

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BEAVER VALLEY - UNIT 1 3/4 3-50 Amendment No. ,

(Proposed Wording) l

TABLE 4.3-7 DPR-66 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REOUIREMENTS CHANNEL CHANNEL CHECK CALIBRATION

1. Pressurizer Water Level M R

2. Auxiliary Feedwater Flow Rate S/U(1) R

3. Reactor Coolant System Subcooling Margin M R

4. PORV Acoustical Detector Position Indicator M R

5. PORV Limit Switch Position Indicator M R

6. PORV Block Valve Limit Switch Position Indicator M R

7. Safety Valve Acoustical Detector Position Indicator N/A R

8. Safety Valve Temperature Detector Position Indicator M R

9. Deleted l

10. Containment Sump Wide-Range Water Level M R

11. Containment Wide-Range Pressure -

N/A R

12. In-Core Thermocouples (Core-Exit Thermocouples) M R

13. Reactor Vessel Level Indicating System M R (1) Channel check to be performed in conjunction with Surveillance Requirement 4.7.1.2.c following an' extended plant outage.

BEAVER VALLEY - UNIT 1 3/4 3-52 Amendment No.

(Proposed Wording)

r.

- ------------- y

~l l

DPR-66 RFACTOR COOLANT SYSTEM OVERPRESSURE PROTECTION SYSTEMS LIMITING CONDITION FOR OPERATION 3.4.9.3 An overpressure shall be OPERABLE-with a maximum of one charging py protect 19g) system capable of injecting into the RCS and the accumulators isolatedtgpt J and either a or b below;

a. Two power operated relief valves (PORVs) with a lift setting less than or equal to 432 psig, or

{

b. The RCS depressurized and an RCS vent of greater than or l equal to 3.14 square inches. '

APPLICABILITY: Mode 4 when any RCS cold leg temperature is'less than or equal to an enable temperature of 329'F, Mode 5, Mode 6 when the reactor vessel head is on. J ACTION:

]

a. With two or m o r e c h a r g i n g p u m p s c'a p a b l e o f i n j e c t i n g i n t o -

the RCS, immediately initiate action to verify a maximum of one charging pump is capable of injecting into the RCS or depressurize and. vent the RCS through a 3.14 square inch or i larger vent within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

l

b. With an accumulator not isolated when the accumulator l pressure is greater than or equal to the maximum RCS I pressure for the existing RCS cold leg temperature allowed-by the heatup and cooldown curves, isolate the affected accumulator within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or increase the RCS cold leg temperature above the enable temperature within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or depressurize the affected accumulator to less than the maximum RCS pressure for the existing cold leg i temperature allowed by thel heatup and cooldown curves- j within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . l

c. With one PORV inoperable in MODE 4 (when any RCS cold leg temperature is less than or . equal to.1the enable temperature), restore the inoperable PORV .to OPERABLE status within 7 days or depressurize and vent the'RCS.

through a 3.14 square inch or larger vent within the next j 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . j (1) Two charging pumps may beicapable of injecting into the-RCS for pump swap operation for less than or equal to 15 minutes.

(2) Accumulator isolation with power removed- from. the' discharge isolation valves is only required when the accumulator pressure-is greater than or equal to the maximum RCS pressure for-the existing RCS cold leg temperature allowed by the heatup and cooldown curves.

BEANER VALLEY - UNIT 1 3/4 4-27a .

Amendment No.

(Proposed Wording) i

T,PR-66 REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

d. With one PORV inoperable in MODES 5 or 6, restore the inoperable PORV to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or depressurize and vent the RCS through a 3.14 square inch or larger vent within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

e. With two PORVs inoperable, depressurize and vent the RCS through a 3.14 square inch or larger vent within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

I SURVEILLANCE REQUIREMENTS 1

4.4.9.3.1 Verify at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that:

l l a. A maximum of one charging pump is capable of injecting into I the RCS, and ,

b. Each accumulator is isolated; however, with the accumulator pressure less than the low temperature overpressure protection setpoint, the accumulator discharge isolation valves may be opened to perform accumulator discharge check valve testing.

4.4.9.3.2 When PORVs are being used for overpressure protection, demonstrate each PORV is OPERABLE by:

a. Verifying each PORV block valve is open for each required PORV at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and

b. Performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation channel, but excluding valve operation, within 31 days prior to entering a condition in which the PORV is required to be OPERABLE and placed in operation after decreasing the RCS cold leg temperature to less than or equal to the enable temperature and at least once per 31 days, and

c. Performance of a CHANNEL CALIBRATION on each required PORV actuation channel at least once per 18 months.

BEAVER VALLEY - UNIT 1 3/4 4-27b Amendment No.

(Proposed Wording) l i

I

---_ - _ _ __-__ -- - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _ - - - a

DPR-66 REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS (Continued) 4.4.9.3.3 When a vent is being used for overpressure protection, verify the required vent is open:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for an open vent or unlocked open vent valve (s), except

b. At least once per 31 days for a valve which is locked or provided with remote position indication, or sealed, or otherwise secured in the open position.

l BEAVER VALLEY - UNIT 1 3/4 4-27c Amendment No.

(Proposed Wording)

b DPR-66 REACTOR COOLANT SYSTM 314.4.11 RELIEF VALVES LIMITING CONDITION FOR OPERATION

=

3.4.11 Each power operated relief valve (PORV) and associated block valve shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3.

ACTION:

- - - - - - - - - - - - - - GENERAL NOTE - - - - - - - - - - - - -

Separate ACTION statement entry is allowed for each PORV and block valve.

a. With one or more PORVs inoperable and capable of being manually cycled, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ei to OPERABLE status or close the a,ther restoreblock ssociated the PORV(s) valve (s) with power maintained to the block valve (s); otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

b. With one or two PORV(s) inoperable and not capable of being manually cycled, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the PORV(s) to OPERABLE status or close the associated block valves and remove power from the block valve (s); a minimum of two PORVs are to be OPERABLE within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With one PORV inoperable and isolated, power operation may continue until the next refueling outage.

c. With three PORVs inoperable and not capable of being manually cycled, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least one PORV to OPERABLE status or close the associated block valves and remove power from the block valves and be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

d. With one block valve inoperable and open, within i hour either restore the block valve to OPERABLE status or place the associated PORV in manual control. Restore the block valve to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or i be in HOT STANDBY with the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN '

l l

l BEAVER VALLEY - UNIT 1 3/4 4-29 Amendment No. I (Proposed Wording)

DPR-66 REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

ACTLQH: (Continued) within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With one block valve inoperable, restore the block valve to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or close it, power operation may continue until the next refueling outage.

e. With more than one block valve inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the block valves to OPERABLE status or place the associated PORVs in manual control. Restore at least one block valve to OPERABLE status within the next hour if three block valves are inoperable; restore a minimum of two block valves to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS ,

4.4.11.1 Each PORV shall be demonstrated OPERABLE at least once per 18 months by operating the PORV through one complete cycle of full travel using:

a) The normal air supply system, and b) The backup nitrogen supply system.

4.4.11.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by operating the valve through one complete cycle of full travel unless the block valve is closed to meet required ACTIONS b or c.

BEAVER VALLEY - UNIT 1 3/4 4-29a Amendment No.

(next page is 3/4 4-32)

(Proposed Wording)

1 i

DPR-66 :

EMERGENCY CORE COOLING SYSTEMS I 1

SURVEILLANCE REQUIREMENTS (Continued)

I

b. At least once per 31 days and within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after each solution volume increase of greater than or equal to l 1 percent of tank volume by verifying the boron concentration of the accumulator solution. !

c. At least once per 31 days when the RCS pressure is above 2000 psig by verifying that power to the isolation valve operator control. circuit is disconnected by removal of the plug in the lock out jack from the circuit.

4.5.1.2 Each accumulator water level and pressure alarm channel shall be demonstrated OPERABLE:

a. At least once per 31 days by the performance of a CHANNEL FUNCTIONAL TEST.

b. At least once per 18 months by the performance of a CHANNEL CALIBRATION. '

BEAVER VALLEY - UNIT 1 3/4 5-2 Amendment No.

(Proposed Wording)

DPR-66 REACTOR COOLANT SYSTEM l

BASES l

3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued) vessel inside radius are essentially identical, the measured transition shift for a sample can be applied with confidence to the adjacent section of the reactor vessel. The heatup and cooldown curves must be recalculated when the ART determined from the surveillance capsule is different from "khe calculated ART NDT for the equivalent capsule radiation exposure.

The pressure-temperature limit lines shown on Ficure 3.4-2 for reactor criticality and for inservice leak and hydrostatic testing have been provided to assure compliance with the minimum temperature requirements of Appendix G to 10 CFR 50 for reactor criticality and for inservice leak and hydrostatic testing.

The number of reactor vessel irradiation surveillance specimens and the frequencias for removing and testing these specimens are provided in UFSAR Table 4.5-3 to assure compliance with the requirements of Appendix H to 10 CFR 50.

The limitations imposed on the pressurizer heatup and cooldown rates and spray water temperature differential are provided to assure that the pressurizer is operated within the design criteria assumed for l the fatigue analysis performed in accordance with the ASME Code requirements.

Pressure-temperature limit curves shown in Figure B 3/4 4-3 were developed for the limiting ferritic steel component within an isolated reactor coolant loop. The limiting component is the steam generator channel head to tubesheet region. This figure provides the ASME III, Appendix G limiting curve which is used to define operational bounds, such that when operating with an isolated loop the analyzed pressure-temperature limits are known. The temperature range provided bounds the expected operating range for an isolated loop.

OVERPRESSURE PROTECTION SYSTEMS BACKGROUND The overpressure protection system (OPPS) controls RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G. The reactor vessel is the limiting RCPB component for demonstrating such protection. The maximum setpoirat for the power operated relief valves (PORVs) and the maxinum RCS pressure for the existing RCS cold leg temperature during cooldown, shutdown, and heatup meet the 10 CFR 50, Appendix G requirements during the OPPS MODES.

BEAVER VALLEY - UNIT 1 B 3/4 4-10 Amendment No.

(Proposed Wording)

DPR-66 EDCTOP COOLANT SYSTEE BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

BACKGROUND (Continued)

The reactor vessel material is less tough at low temperatures than at normal operating temperature. As the -vessel neutron exposure accumulates, the material toughness decreases and becomes less resistant to pressure stress at ~1ow temperatures. RCS pressure, therefore, is maintained low at low temperatures and is increased only as temperature is increased.

The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only during shutdown; a pressure f1cetuation can occur more quickly than an operator can react to relieve the condition. Exceeding the RCS P/T limits by a significant amount could cause brittle cracking of the reactor vessel. LCO 3.4.9.1, " Pressure / Temperature Limits," requires administrative control of RCS pressure and temperature duri,ng heatup and cooldown to prevent exceeding the limits.

This LCO provides RCS overpressure protection by leaving a minimum coolant input capability and having adequate pressure relief capacity. Limiting coolant input capability requires deactivating all but one charging pump 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 device that acts to terminate an increasing pressure event.

With minimum coolant input capability, the ability to provide core coolant addition is restricted. The LCO does not require the makeup control system deactivated or the safety injection (SI) actuation circuits blocked. Due to the lower pressures in the OPPS MODES and the expected core decay heat levels, the makeup system can provide adequate flow via the makeup control valve and, if needed, until the charging pump is actuated by SI.

The OPPS for pressure relief consists of two PORVs with reduced lift settings or a depressurized RCS and an RCS vent of sufficient size.

Two RCS relief valves are required for redundancy. One RCS relief valve- has adequate relieving capability to keep from overpressurization for the required coolant input capability.

BEAVER VALLEY - UNIT 1 B 3/4 4-10a Amendment No. l (Proposed Wording) l

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS / Continued)

EORV REOUIREMENTS As designed for the OPPS System, each PORV is signaled to open if the RCS pressure approaches a limit determined by the OPPS actuation circuit. The OPPS actuation circuit monitors RCS pressure and determines when a condition not acceptable is approached. If the indicated pressure meets or exceeds the OPPS actuation setpoint, a PORV is signaled to open. Having the setpoints of both valves within the limits ensures that the Appendix G limits will not be exceeded in any analyzed event. When a PORV is opened in an increasing pressure transient, the release of coolant will cause the pressure increase to slow and reverse. As the PORV releases coolant, the RCS pressure decreases until a reset pressure is reached and the valve is signaled to close. The pressure continues to decrease below the reset pressure as the valve closes.

1 RCS VENT REOUIREMENTS Once the RCS is depressurized, a vent exposed to the containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the relieving requirements of the transient do not exceed the capabilities of the vent. Thus, the vent path must be capable of relieving the flow resulting from the limiting OPPS mass or heat input transient, and maintaining pressure below the P/T limits. The required vent capacity may be provided by one or more vent paths.

For an RCS vent to meet the flow capacity requirement, it may be satisfied by removing a pressurizer safety valve or establishing an ,

opening between the RCS and the containment atmosphere of the i required size through any positive means available which cannot be I inadvertently defeated. The vent path (s) must be above the level of I reactor coolant, so as not to drain the RCS when open. )

APPLICABLE SAFETY ANALYSES l

Safety analyses demonstrate that the reactor vessel is adequately l protected against exceeding the P/T limits when low RCS temperature i conditions exist. At the enable temperature and below, overpressure -

prevention is provided by two OPERABLE RCS relief valves or a l depressurized RCS and a sufficient sized RCS vent.

BEAVER VALLEY - UNIT 1 B 3/4 4-10b Amendment No. I (Proposed Wording)

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

APPLICABLE SAFETY ANALYSES (Continued)

The actual temperature at which the pressure in the P/T limit curve falls below the OPPS setpoint increases as the reactor vessel material toughness decreases due to neutron embrittlement. Each time the heatup and cooldown curves are revised, the OPPS must be re-evaluated to ensure its functional requirements can still be met.

The heatup and cool 6own curves represent the Appendix G limits that define OPPS operation. Setpoint calculations correlated to RCS temperature define acceptable OPPS setpoints for steady state pressure-temperature limits based on Revision 2 of NRC Regulatory Guide 1.99. Any change to the RCS that may affect OPPS operation must be evaluated against the analyses to determine the impact of the change on the OPPS acceptance limits.

Transients that are capable of overpr'essurizing the RCS are categorized as either mass or heat input transients, examples of which follow:

MASS INPUT TYPE TRANSIENTS

a. Inadvertent safety injection; or

b. Charging / letdown flow mismatch.

HEAT INPUT TYPE TRANSIENTS

a. Inadvertent actuation of pressurizer heaters;

b. Loss of RHR cooling; or

c. Reactor coolant pump (RCP) startup with temperature asymmetry within the RCS or between the RCS and steam generators.

The following are required during the OPPS MODES to ensure that mass and heat input transients do not occur, which either of the OPPS overpressure protection means cannot handle:

a. Deactivating all but one charging pump OPERABLE;

b. Deactivating the accumulator discharge isolation valves in their closed positions; and BEAVER VALLEY - UNIT 1 B 3/4 4-10c Amendment No. l (Proposed Wording)

l DPR-66' l REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

HEAT INPUT TYPE TRANSIENTE (Continued)

c. Disallowing start of an RCP if secondary temperature is more than 25'F above primary temperature in any one loop. LCO 3.4.1.6, " Reactor Coolant Pump Startup," provides this protection.

The analyses demonstrate that either one RCS relief valve or the depressurized RCS and RCS vent can maintain the RCS pressure below the limits when only one charging pump is actuated by SI. Thus, the LCO allows only one charging pump OPERABLE during the OPPS MODES.

Since neither one RCS relief valve nor the RCS vent can handle a full SI actuation, the LCO also requires the accumulators. isolated.

The isolated accumulators must have their discharge valves closed with power removed. Fracture mechanics analyses established the temperature of OPPS Applicability at the enab'le temperature.

PORV PERFORMANCE The fracture mechanics analyses show that the vessel is protected when the PORVs are set to open at or below the limit. The setpoint is derived by analyses that model the performance of the OPPS assuming ~ the limiting OPPS transient of SI actuation of one charging pump. These analyses consider pressure overshoot and undershoot beyond the PORV opening and closing, resulting from signal processing and valve stroke times. The PORV setpoints at or below the derived limit ensures the P/T limits will be met.

The PORV setpoint will be updated when the revised P/T limits conflict with the OPPS analysis limits. The P/T limits are periodically modified as the reactor vessel material toughness decreases due to neutron embrittlement caused by neutron irradiation. Revised limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens. The Bases for LCO 3.4.9.1, " Pressure / Temperature Limits," discuss these examinations.

The PORVs are considered active components. Thus, the failure of one PORV is assumed to represent the worst case, single active failure.

RCS VENT PERFORMANCE With the RCS depressurized, analyses show that a PORV or equivalent opening with a vent size of 3.14 square inches is capable of mitigating the allowed OPPS overpressure transient. The capacity of BEAVER VALLEY - UNIT 1 B 3/4 4-10d Amendment No. l (Proposed Wording)

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3 /4.4.9 PRESSURE / TEMPERATURE LIMITS _(Continued)

RCS VENT PERFORMAl{CE (Continued) a vent this size is greater than the flow of the limiting transient for the OPPS configuration, SI actuation with one charging pump OPERABLE, maintaining RCS pressure less than the maximum pressure on the P/T limit curve.

The RCS vent size is based on the PORV size, therefore, the vent is bounded by the PORV analysis.

The RCS vent is passive and is not subject to active failure.

LCQ This LCO requires that the OPPS is OPERABLE. The OPPS is OPERABLE when the minimum coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could' lead to the locs of low temperature overpressure mitigation and violation of the limits as a result of an operational transient.

To limit the coolant input capability, the LCO requires one charging pump capable of injecting into the RCS and all accumulator discharge isolation valves closed and immobilized. The LCO is qualified by a note that permits two pumps capable of RCS injection for less than or equal to 15 minutes to allow for pump swaps.

The LCO is also qualified by a note stating that accumulator isolation with power removed from the discharge isolation valves is only required when the accumulator pressure is greater than or at the maximum RCS pressure for the existing temperature, as allowed by the P/T limit curves. This note permits the accumulator discharge isolation valve surveillance to be performed only under these pressure and temperature conditions.

The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

a. Two OPERABLE PORVs; a PORV is OPERABLE for OPPS when its block valve is open, its lift setpoint is set to the limit and testing proves its ability to open at this setpoint, and motive power is available to the two valves and their control circuits; or

b. A depressurized RCS and an RCS vent.

BEAVER VALLEY - UNIT 1 B 3/4 4-10e Amendment No. l (Proposed Wording)

i l

l DPR-66 !

REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

LCQ (Continued)

An RCS vent is OPERABLE when open with an area of 3.14 square inches.

Each of these methods of overpressure prevention is capable of mitigating the limiting OPPS transient.

APPLICABILITY This LCO is applicable in MODE 4 when any RCS cold leg temperature is less than or equal to the enable temperature, in MODE 5, and in MODE 6 when the reactor vessel head is on. When the reactor vessel head is off, overpressurization cannot occur.

Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, a mass or heat input transient can cause a very rapid increase in,and RCS pressure when little or no time allows operator action to mitigate the event.

ACTION

a. With two or more charging pumps capable of injecting into the RCS, RCS overpressurization is possible.

To immediately initiate action to restore restricted coolant input capability to the RCS reflects the urgency of removing the RCS from this condition.

b. An unisolated accumulator requires isolation within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

This is only required when the accumulator pressure is at or more than the maximum RCS pressure for the existing temperature allowed by the P/T limit curves.

If isolation is needed and cannot be accomplished in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the ACTION provides two options, either of which must be performed in the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . By increasing the RCS temperature to more than the enable temperature, the accumulator pressure cannot exceed the OPPS limits if the accumulators are fully injected. Depressurizing the accumulators below the OPPS limit also gives this protection.

The completion times are based on operating experience that these activities can be accomplished in these time periods indicating that an event requiring OPPS is not likely in the allowed times.

l BEAVER VALLEY - UNIT 1 B 3/4 4-10f Amendment No. l (Proposed Wording)

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (ContinggdQ ACTION (Continued)

c. In MODE 4 when any RCS cold leg temperature is less than or equal to the enable temperature, with one required RCS relief valve inoperable, the RCS relief valve must be restored to OPERABLE status within a completion time of 7 days. Two RCS relief valves are required to provide low temperature overpressure mitigation while withstanding a single failure of an active component.

The completion time considers the facts that only one of the RCS relief valves is required to mitigate an overpressure transient and that the likelihood of an active failure of the remaining valve path during this time period is very low. If plant operation results in transitioning to MODE 5, the completion time to restore An inoperable PORV may not exceed 7 days as required by this ACTION.

d. The consequences of operational events that will overpressurize the RCS are more severe at lower temperature. Thus, with one of the two RCS relief valves inoperable in MODE 5 or in MODE 6 with the head on, the completion time to restore two valves to OPERABLE status is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The completion time represents a reasonable time to investigate and repair several types of relief valve failures without exposure to a lengthy period with only one OPERABLE RCS relief valve to protect against overpressure events. If a PORV is inoperable when the plant enters MODE 5 from MODE 4, the completion time' to restore an inoperable PORV changes to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months but the cumulative inoperable time may not exceed 7 days before taking action to depressurize and vent,

e. The RCS must be depressurized and a vent must be established within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when both required RCS relief valves are inoperable. The vent must be sized greater than or equal to 3.14 square inches to ensure that the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES. This action is needed to protect the RCPB from a low temperature overpressure event and a possible brittle failure of the reactor vessel.

BEAVER VALLEY - UNIT 1 B 3/4 4-10g Amendment No. l (Proposed Wording)

DPR-66 REACTOR COOLANT SYSTEM

~ BASES (Continued)

-3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

ACTION (Continued)

The completion time considers the time required to place the plant in this condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements.

SURVEILLANCE REOUIREMENTS (SR)

SR 4.4.9.3.1 To minimize the potential for a low temperature overpressure event by limiting the mass input capability, a maximum of one charging pump is OPERABLE with the others verified deactivated with power removed and the accumulator discharge isolation valve,s are verified closed and locked out.

The frequency of 12 hours is sufficient, considering other indications and alarms available to the operator in the control room, to verify the required status of the equipment.

SR 4.4.9.3.1.b allows opening the accumulator discharge isolation valves to perform accumulator discharge check valve testing.

SR 4.4.9.3.2 The PORV block valve must be verified open every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to provide the flow path for each required PORV to perform its function when actuated. The valve must be remotely verified open in the main control room. This surveillance is performed if the PORV satisfies the LCO.

The block valve is a remotely controlled, motor operated valve. The power to the valve operator is not required removed, and the manual operator is not required locked in the inactive position. Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months frequency is considered adequate in view of other administrative controls available to the operator in the control room, such as valve position indication, that verify that the PORV block valve remains open.

l BEAVER VALLEY - UNIT 1 B 3/4 4-10h Amendment No. l' (Proposed Wording)

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

SURVEILLANCE REOUIREMENTS (SR) (Continued)

The SR is required to be performed prior to entering the condition for the OPPS to be OPERABLE. This assures low temperature overpressure protection is available when the RCS cold leg temperature is less than or equal to the enable temperature.

Performing the surveillance every 31 days on each required PORV permits verification and adjustment, if necessary, of its lift setpoint, and considers instrumentation reliability which has been shown through operating experience to be acceptable. The CHANNEL FUNCTIONAL TEST will verify the setpoint is within the allowed maximum limits. PORV actuation could depressurize the RCS and is not required.

Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 months to ad that it responds and. the valve opens with'just therequired in the whole channel range andso accuracy to known input.

SR 4.4.9.3.3 The RCS vent of greater than or equal to 3.14 square inches is proven OPERABLE by verifying its open condition either:

a. Once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for an open vent or valve that cannot be locked, except

b. Once every 31 days for a valve that is locked, or provided with remote position indication, or sealed, or secured in position. A removed pressurizer safety valve fits this category.

The passive vent arrangement must only be open to be OPERABLE. This surveillance is required to be performed if the vent is being used to satisfy the pressure relief requirements of the LCO.

BEAVER VALLEY - UNIT 1 B 3/4 4-101 Amendment No. l (Proposed Wording)

DPR-66 REACTOR COOLANT SYSTEM BASES 3/4.4.10 STRUCTURAL INTEGRITY The inservice inspection and testing programs for ASME Code Class 1, 2, and 3 components ensure that the structural integrity and operational readiness of these components will be maintained at an acceptable level throughout the life of the plant. These programs are in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50.55a(g) except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50.55a(g) (6) (i) .

3/4.4.11 RELIEF VALVES BACKGROUND The Pressurizer is equipped with two types of devices for pressure relief: pressurizer safety valves and PORVs. The PORVs are air operated valves that are controlled to open at a specific set pressure when the p r e s s u r i z e r p r e s s u r e i n c'r e a s e s a n d c l o s e w h e n t h e pressurizer pressure decreases. The PORVs may also be manually operated from the control room.

Block valves, which are normally open, are located between the pressurizer and the PORVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room.

A stuck open PORV is, in effect, a small break loss of coolant accident (LOCA). As such, block valve closure terminates the RCS depressurization and coolant inventory loss.

The PORVs and their associated block valves may be used by plant operators to depressurize the RCS to recover from certain transients if normal pressurizer spray is not available. Additionally, the-series arrangement of the PORVs and their block valves permit performance of certain surveillances on the valves during power operation.

The PORVs may also be used for feed and bleed core cooling in the case of multiple equipment failure events that are not within the design basis, such as a total loss of feedwater.

The PORVs, their block valves, and their controls are powered from emergency power sources in the event of a loss of offsite power. Two PORVs and their associated block valves are powered from two separate safety trains.

1 l

BEAVER VALLEY - UNIT 1 B 3/4 4-11 Amendment No. l (Proposed Wording) i

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 RELIEF VALVES (Continued)

BACKGROUND (Continued)

The plant has three PORVs, each having a relief capacity of 210,000 lb/hr at 2350 psig. The functional design of the PORVs is based on maintaining pressure below the high pressure reactor trip setpoint.

In addition, the PORVs minimize challenges to the pressurizer safety valves and also may be used for low temperature overpressure protection (OPPS). See LCO 3.4.9.3, " Overpressure Protection System."

APPLICABLE SAFETY ANALYSES Plant operators employ the PORVs to depressurize the RCS in response to certain plant transients if normal pressurizer spray is not available. For the Steam Generator Tube Rupture (SGTR) event, the safety analysis assumes that. manual operator actions are required to mitigate the event. A loss of offsite powe'r is assumed to accompany the event, and thus, normal pressurizer spray is unavailable to reduce RCS pressure. The PORVs are assumed to be used for RCS depressurization, which is one of the steps performed to equalize the primary and secondary pressures in order to terminate the primary to secondary break flow and the radioactive releases from the affected steam generator.

The PORVs are used in safety analyses for events that result in increasing RCS pressure for which departure from nucleate boiling ratio (DNBR) criteria are critical. Certain analyses have been performed to study the effects on primary pressure assuming PORV actuation. The results of the loss of external load and/or a turbine trip event indicate the primary pressure remains within the design limits and the DNBR is maintained within the acceptance criteria.

LCQ The LCO requires the PORVs and their associated block valves to be OPERABLE for manual operation to mitigate the effects associated with an SGTR.

By maintaining at least two PORVs and their associated block valves OPERABLE, redundancy has been provided. The block valves are ;

available to isolate the flow path through either a failed open PORV l or a PORV with excessive leakage. Satisfying the LCO helps minimize challenges to fission product barriers.

l BEAVER VALLEY - UNIT 1 B 3/4 4-11a .

Amendment No. l (Proposed Wording) l l

l

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 RELIEF VALVES (Continued)

APPLICABILITY In MODES 1, 2, and 3, the PORV and its block valve are required to be OPERABLE to limit the potential for a small break LOCA through the flow path. The most likely cause for a PORV small break LOCA is a result of a pressure increase transient that causes the PORV to open. Imbalances in the energy output of the core and heat removal by the secondary system can cause the RCS pressure to increase to the PORV opening setpoint. The most rapid increases will occur at the higher operating power and pressure conditions of MODES 1 and 2. The PORVs are also required to be OPERABLE in MODES 1, 2, and 3 to minimize challenges to the pressurizer safety valves.

Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. Therefore, the LCO is applicable in MODES 1, 2, And 3. The LCO is not applicable in MODE 4 when both pressure and core energy are decreased and the pressure surges become much less significant. The PORV setpoint is reduced for OPPS in MODES 4 (below the enable temperature), 5, and 6 with the reactor vessel head in place. LCO 3.4.9.3 addresses the PORV requirements in these MODES.

ACTION A General Note provides clarification that all pressurizer PORVs and block valves are treated as separate entities, each with separate completion times (i.e., the completion time is on a component basis),

a. With the PORVs inoperable and capable of being manually cycled, either the PORVs must be restored or the flow path isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The block valves should be closed but power must be maintained to the associated block valves, !

since removal of power would render the block valve '

inoperable. Although a PORV may be designated inoperable, it may be able to be manually opened and closed, and therefore, able to perform its function. PORV inoperability may be due to seat leakage, instrumentation problems related to PORV accident monitoring instruments identified in LCO 3.3.3.8, or other causes that do not prevent manual use and do not create a possibility for a small break LOCA. If the position indication is inoperable, then the PORVs are inoperable. For these reasons, the block valve shall be closed but the ACTION requires power be maintained to the i valve. Automatic control problems and .related I instrumentation problems would not render the PORVs inoperable. Accident analyses assume manual operation of l

l BEAVER VALLEY - UNIT 1 B 3/4 4-11b Amendment No. l l (Proposed Wording) )

i

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 RELIEF VALVES (Continued)

ACTION (Continued) the PORVs and does not take credit for automatic actuation.

This condition is only intended to permit operation of the plant for a limited period of time not to exceed the next refueling outage (MODE 6) so that maintenance can be performed on the PORVs to eliminate the seat leakage condition. Normally, the PORVs should be available for automatic mitigation of overpressure events and should be returned to OPERABLE status prior to entering startup (MODE 2).

Quick access to the PORV for pressure control can be made when power remains on the closed block valve. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is based on plant operating experience that has shown that minor problems can be corrected or closure accomplished in'this time period,

b. With one or two PORV(s) inoperable and not capable of being manually cycled, the PORV(s) must be either restored or isolated by closing the associated block valve and removing the power to the associated block valve. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on challenges to the PORVs during this time period, and provides the operator adequate time to correct the situation. If the inoperable valve (s) cannot be restored to OPERABLE status, the PORV(s) must be isolated within the specified time. Because there is at least one PORV that remains OPERABLE, an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is provided to restore a minimum of two PORVs to OPERABLE status. If a minimum of two PORVs cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply. Two OPERABLE PORVs provide redundancy to allow continued operation until the next refueling outage to perform maintenance on the inoperable valve and return it to OPERABLE status.

c. If three PORVs are inoperable and not capable of being manually cycled, it is necessary to either restore at least one valve within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or isolate the flow path by closing and removing the power to the associated block valves. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. If one PORV is restored, then the BEAVER VALLEY - UNIT 1 B 3/4 4-11c Amendment No. l (Proposed Wording)

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 RELIEF VALVES (Continued)

ACTION (Continued) plant will be in a less limiting ACTION statement with the time clock started at the original declaration of having three PORVs inoperable. If no PORVs are restored within the completion time, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed completion times are reasonable, based' on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, maintaining PORV OPERABILITY may be required. See LCO 3.4.9.3.

d. If one block valve is inoperable and open, then it is necessary to either rostore the' block valve to OPERABLE status within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or place the associated PORV in manual control. The prime importance for the capability to close the block valve is to isolate a stuck open PORV. Therefore, if the block valve cannot be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the required action is to place the PORV in manual control to preciade its automatic opening for an overpressure event and to avoid the potential for a stuck open PORV at a time that the block valve is inoperable. If the block valve in inoperable, it is necessary to restore the block valve to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or close it. If block valve instrumentation related to accident monitoring instrumentation identified in LCO 3.3.3.8 is determined to be inoperable, then the block valve shall be declared inoperable. Closing the block valve precludes the need to place the PORV in manual control since it is isolated from the system. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time period, and provides the operator time to correct the situation.

Because at least one PORV remains OPERABLE, the operator is permitted a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the !

inoperable open block valve to OPERABLE status. If it I cannot be restored within this additional time, the plant i

must be brought to a MODE in which the LCO does not apply in j order to avoid continuous operation without a redundant ;

ability to isolate this PORV flow path. If the block valve ,

is restored within the completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the i power will be restored and the PORV restored to OPERABLE i status. With one block valve inoperable and closed, there BEAVER VALLEY - UNIT 1 B 3/4 4-11d Amendment No. I I (Proposed Wording) )

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 RELIEF VALVES (Continued)

ACTION (Continued) still remains two PORV flow paths. This redundancy will allow continued operation until the next refueling outage to perform maintenance on the inoperable valve and return it to OPERABLE status,

e. If more than one block valve is inoperable, it is necessary to either restore the block valves within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or place the associated PORVs in manual control and restore at least one block valve within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (and restore a minimum of two block valves within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ). Two OPERABLE PORVs provide redundancy to allow continued operation until the next refueling outage to-perform maintenance on the inoperable valve and return it to OPERABLE status. The completion times are reasonable, based ,

on the small potential for challenges to the system during I this time and provide the operator time to correct the situation. If the required actions are not met, then the plant must be brought to a MODE in which the LCO does not !

apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed completion times are reasonable, based I

on operating experience, to reach the required plant conditions from full power conditions in an orderly manner J and without challenging plant systems. In MODES 4 and 5, j maintaining PORV OPERABILITY may be required.

3.4.9.3.

See LCO l SURVEILLANCE REOUIREMENTS (SR)

SR 4.4.11.1 This surveillance requires a complete cycle of each PORV. Operating a PORV through one complete cycle ensures that the PORV can be l

manually actuated for mitigation of an SGTR. The frequency of 18 months is based on a typical refueling cycle and industry accepted practice. Cycling the PORVs using both the normal air supply system and the backup nitrogen supply system actuates the solenoid control l valves and check valves to ensure the PORV control system will actuate properly when called upon. Testing in this manner assures each component within the PORV control system necessary to support PORV operation has been determined to function satisfactorily.

l BEAVER VALLEY - UNIT 1 B 3/4 4-11e Amendment No. l (Proposed Wording)

1 l

DPR-66 REACTOR COOLANT SYSTEM BASES (Continued)

SURVEILLANCE REOUIREMENTS (SR) (Continued)

SR 4.4.11.2 Block valve cycling verifies that needed. The basis the valve (s) can be closed if Section XI.

for the frequency of 92 days is the ASME Code, capable of If the block valve is closed to isolate a PORV that is being manually cycled, the OPERABILITY of the block valve is of importance, because opening the block valve is necessary to permit the PORV to be used for manual control of reactor pressure.

If the block valves are closed to isolate otherwise inoperable PORVs, the maximum completion time to restore the PORV and open the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , which is well within the allowable limits (25%) to extend the block valve frequency of 92 days. Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e.,

completion of the required actions fulfills the SR).

ii This SR is not required to be met with the block valve closed, in accordance with required ACTIONS b or c of this LCO.

3/4.4.12 REACTOR COOLANT SYSTEM VENTS Reactor Coolant System Vents are provided to exhaust noncondensable gases and/or steam from the primary system that could inhibit natural circulation core cooling.

coolant system vent path from The OPERABILITY of at least one reactor the reactor vessel head and the pressurizer steam space, ensures the capability exists to perform this function.

The valve redundancy of the reactor coolant system vent paths serves to minimize the probability of inadvertent or irreversible actuation while ensuring that a single failure of a vent valve, power supply or control system does not prevent isolation of the vent path.

The function, capabilities, and testing requirements of the reactor coolant system vent systems are consistent with the requirements of Item II.B.1 of NUREG-0737, " Clarification of TMI Action Plan i Requirements," November 1980.

l

(

BEAVER VALLEY - UNIT 1 B 3/4 4-11f Amendment No. I (Proposed Wording) s

-__ = _---__ - __- - - -

ATTACHMENT C-2 Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification Change No. 49 TYPED PAGES Applicable Typed Pages l

l I

I

ATTACEMENT TO LICENSE AMENDMENT NO.

FACILITY OPERATING LICENSE NO. NPF-73 DOCKET NO. 50-412 Replace the following pages of Appendix A, Technical Specifications, with the enclosed pages as indicated. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

1 Remove Insert 3/4 1-10 3/4 1-10 3/4 1-11 3/4 1-11 3/4 3-57 3/4 3-57 3/4 4-35 3/4 4-35 3/4 4-36 3/4 4-36 3/4 4-36a

'3/4 4-39 3/4 4-39 3/4 4-39a 3/4 5-2 3/4 5-2 B 3/4 4-14 B 3/4 4-14 B 3/4 4-15 B 3/4 4-15 B 3/4 4-15a B 3/4 4-15b B 3/4 4-15c B 3/4 4-15d B 3/4 4-15e B 3/4 4-15f B 3/4 4-15g B 3/4 4-15h B 3/4 4-151 B 3/4 4-16 B 3/4 4-16 ;

B 3/4 4-16a B 3/4 4-16b i B 3/4 4-16c B 3/4 4-16d B 3/4 4-16e l B 3/4 4-16f l 6-19 6-19 )

(Proposed Wording)

NPF-73 REACTIVITY CONTROL SYSTEMS CHARGING PUMP-SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.3 At least one charging pump (l) in the boron injection flow path required by Specification 3.1.2.1 or low head safety injectica pump (with an open Reactor Coolant System vent of greater than or equal to 3.14 square inches) shall be OPERABLE and capable of being powered from an OPERABLE emergency bus.

APPLICABILITY: MODES 4, 5 and 6.

ACTION:

With none of the above pumps OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes until one charging pump or low head safety injection pump is restored to l OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.1.2.3.1 The above required charging pump shall be demonstrated OPERABLE by verifying, that on recirculation flow, the pump develops a differential pressure of greater than or equal to 2437 psid when tested pursuant to Specification 4.0.5.

4.1.2.3.2 When the low head safety injection pump is used in lieu of a charging pump, the low head safety injection pump shall be demonstrated OPERABLE by:

a. Verification of an OPERABLE RWST pursuant to 4.1.2.7 and 4.1.2.8

b. Verification of an OPERABLE low head safety injection pump l pursuant to Specification 4.5.2.b.2,

c. Verification of an OPERABLE low head safety injection flow path I from the RWST to the Reactor Coolant System once per shift, and

d. Verification that the vent is open in accordance with 4.4.9.3.3.

(1) With two charging pumps OPERABLE, follow Specification 3.4.9.3.

BEAVER VALLEY - UNIT 2 3/4 1-10 Amendment No.

(Proposed Wording)

NPF-73 REACTIVITY CONTROL SYSTEMS CHARGING PUMPS-OPERATING j i

l LIMITING CONDITION FOR OPERATION 3.1.2.4 At least two charging pumps shall be OPERABLE.

APPLICABILITY: MODES 1, 2 and 3 (1) , l ACTION:

With only one charging pump OPERABLE, restore at least two charging pumps to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in at least HOT STANDBY and borated to a SHUTDOWN MARGIN equivalent to at least 1 percent Ak/k at 200*F within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; restore at least I two charging pumps to OPERABLE status within the next 7 days or be in HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS i

4.1.2.4.1 At least two charging pumps shall be demonstrated OPERABLE by verifying, that on recirculation flow, each pump develops a differential pressure of greater than or equal to 2437 psid when l tested pursuant to Specification 4.0.5.

t (1) The provisions of Specification 3.0.4 and 4.0.4 are not l applicable for entry into MODE 3 for the centrifugal charging pump declared -inoperable pursuant to Specification 3.4.9.3 l provided that the centrifugal charging pump is restored to OPERABLE status within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or prior to the temperature of one or more of the RCS cold legs exceeding 375'F, whichever comes first.

BEAVER VALLEY - UNIT 2 3/4 1-11 Amendment No.

(Proposed Wording)

NPF-73 INSTRUMENTATION ACCIDENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.8 The accident monitoring instrumentation channels shown in Table 3.3-11 shall be OPERABLE. l APPLICABILITY: MODES 1, 2 and 3.

ACTION:

a. With the number of OPERABLE accident monitoring instrumentation channels less than the Total Number of Channels shown in Table 3.3-11, either restore the inoperable I channel (s) to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (follow Specification 3.4.11 when determining ACTIONS for Items 4 and 5).

b. With the number of OPERABLE accident monitoring instrumentation channels less than the Minimum Channels OPERABLE requirements of Table 3 .'3 - 1 1 , either restore the I inoperable channel (s) to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

c. With the number of OPERABLE Reactor Coolant System Subcooling Margin Monitor instrumentation channels less than the Minimum Channels OPERABLE requirements of Table 3.3-11, either i restore the inoperable channel (s) to OPERABLE status within 7 days or be in a least HOT SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

d. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS I 4.3.3.8 Each accident monitoring instrumentation channel shall l be demonstrated OPERABLE by performance of the CHANNEL CHECK and CHANNEL CALIBRATION operations at the frequencies sLown in Table j 4.3-7. l l

/

I l

BEAVER VALLEY - UNIT 2 3/4 3-57 Amendment No.

(Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM OVERPRESSURE PROTECTION SYSTEMS LIMITING CONDITION FOR OPERATION 3.4.9.3 An overpressure pro g tion system shall be OPERABLE with a maximum of one charging p capable of injecting into the RCS and the accumulators isolatedtgpp I and either a or b below:

l a. Two power-operated relief valves (PORVs) with nominal maximum j lift settings which vary with the RCS temperature and which do i

not exceed the limits established in Figure 3.4-4, or

b. The RCS depressurized and an RCS vent of greater than or equal to 3.14 square inches.

APPLICABILITY: MODE 4 when any RLS cold leg temperature is less than or equal to an enable temperature of 350*F, .

MODE 5, l MODE 6 when the reactor vessel head is on. I ACTION: i !

a. With two or more charging pumps capable of injecting into the RCS, immediately initiate action to verify a maximum of one charging pump is capable of injecting into the RCS or depressurize and vent the RCS through a 3.14 square inch or larger vent within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b. With an accumulator not isolated when the accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the heatup and cooldown curves, isolate the affected accumulator within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or increase the RCS cold leg temperature above the enable temperature within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or depressurize the affected accumulator to less than the maximum RCS pressure for the existing cold leg temperature allowed by the heatup and cooldown curves within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

I (1) Two charging pumps may be capable of injecting into the RCS for pump swap operation for less than or equal to 15 minutes.

All charging pumps may be capable of injecting into.the RCS for less than or equal to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months immediately following a change from MODE 3 to MODE 4 or prior to the temperature of one or more of the RCS cold legs decreasing below 325'F, whichever comes first.

(2) Accumulator isolation with power removed from the discharge isolation valves is only required when the accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the heatup and cooldown curves.

BEAVER VALLEY - UNIT 2 3/4 4-35 Amendment No.

(Proposed Wording)

.. _ _ _ _ _ - - - - _ - - - _ - - - _ - _ _ - - - - - i

NPF-73 REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

c. With one PORV inoperable in MODE 4 (when any RCS cold leg temperature is less than or equal to the enable temperature),

restore the inoperable PORV to OPERABLE status uithin 7 days or depressurize and vent the RCS through a 3.14 square inch or larger vent within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The provisions of Specification 3.0.4 are not applicable when in this action.

d. With one PORV inoperable in MODES 5 or 6, restore the j inoperable PORV to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or depressurize and vent the RCS through a 3.14 square inch or larger vent within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

l l e. With two PORVs inoperable, depressurize and vent the RCS I through a 3.14 square inch or larger vent within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

i SURVEILLANCE REQUIREMENTS 4.4.9.3.1 Verify at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months that:

a. A maximum of one charging pump is capable of injecting into the RCS, and

b. Each accumulator is isolated; however, with the accumulator pressure less than the low temperature overpressure protection setpoint, the accumulator discharge isolation valves may be opened to perform accumulator discharge check valve testing.

4.4.9.3.2 When PORVs are being used for overpressure protection, demonstrate each PORV is OPERABLE by:

a. Verifying each PORV block valve is open for each required PORV at least once per 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , and

b. Performance of a CHANNEL FUNCTIONAL TEST on the PORV actuation channel, but excluding valve operation, within 31 days prior to entering a condition in which the PORV is required to be OPERABLE and placed in operation after decreasing the RCS cold leg temperature to less than or equal to the enable temperature and at least once per 31 days, and

c. Performance of a CHANNEL CALIBRATION on each required PORV actuation channel at least once per 18 months.

BEAVER VALLEY - UNIT 2 1/4 4-36 Amendment No.

(Prr)osed Wording)

NPF-73 )

REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS (Continued) l 4.4.9.3.3 When a vent is being used for overpressure protection, verify the required vent is open:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for an open vent or unlocked open vent valve (s), except

b. At least once per 31 days for a valve which is locked, or provided with remote position indication, or sealed, or otherwise secured in the open position. ]

l l

1 BEAVER VALLEY - UNIT 2 3/4 4-36a Amendment No.

(Proposed Wording)

l NPF-73 I

REACTOR COOLANT SYSTEM 3/4.4.11 RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.11 Each power-operated relief valve (PORV) and associated block valve shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3 ACTION:

- - - - - - - - - - - - - - - GENERAL NOTE - - - - - - - - - - - - -

Separate Action statement entry is allowed for each PORV and block valve.

a. With one PORV inoperable, within 'l hour either restore the PORV to OPERABLE status or close the associated block valve and remove power from the block valve; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Power operation may continue until the next refueling outage,

b. With two PORVs inoperable, within i hour either restore the PORVs to OPERABLE status or close the associated block valves and remove power from the block valves; restore at least one PORV to OPERABLE status within the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

c. With three PORVs inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore at least one PORV to OPERABLE status or close the associated block valves and remove power from the block valves and be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

d. With one block valve inoperable and open, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the block valve to OPERABLE status or place the associated PORV in manual control. Restore the block valve to OPERABLE status with the following 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With one block valve inoperable, restore the block valve to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or close it, power operation may continue until the next refueling outage.

BEAVER VALLEY - UNIT 2 3/4 4-39 Amendment No.

(Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

e. With more than one block valve inoperable, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months either restore the block valves to OPERABLE status or place

the associated PORVs in manual control. Restore at leas + .e block valve to OPERABLE status within the next hour if <

block valves are inoperable; restore a minimum of two b.. .a valves to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ; otherwise, be in HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS !

4.4.11.1 Each PORV shall be demonstrated OPERABLE at least once per 18 months by operating the PORV through one complete cycle of full travel. ,

4.4.11.2 Each block valve shall be demonstrated OPERABLE at least once per 92 days by operating the valve through one complete cycle of full travel unless the block valve is closed to meet required ACTIONS a, b, or c.

l BEAVER VALLEY - UNIT 2 3/4 4-39a Amendment No. l (Proposed Wording)

NPF-73 EMERGENCY CORE COOLING SYSTD!S SURVEILLANCE REQUIREMENTS (Continued)

c. At least once per 31 days when the RCS pressure is'above.

1000 psig by verifying that power to the isolation valve operator control circuit is disconnected by removal of the plug in the lock out jack from the circuit.-

4.5.1.2 Each accumulator water level and pressure alarm channel '

shall be demonstrated OPERABLE:

a. At least once per 31 days by the performance of a CHANNEL FUNCTIONAL TEST.

b. At least once per 18 months by the performance of a CHANNEL CALIBRATION. >

e i

9 9

b BEAVER VALLEY - UNIT 2 3/4 5-2 Amendment'No.

(Proposed Wording) i

'1

NPF-73 REACTOR COOLANT SYETf,H BASES 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

The pressure-temperature limit lines shown on Figure 3.4-2 for reactor criticality and for inservice leak and hydrostatic testing have been provided to assure compliance with the minimum temperature requirements of Appendix G to 10 CFR 50 for reactor criticality and for inservice leak and hydrostatic testing.

The number of reactor vessel irradiation surveillance specimens and the frequencies for removing and testing these specimens are provided in UFSAR Table 5.3-6 to assure compliance with the requirements of Appendix H to 10 CFR Part 50.

The limitations imposed on the pressurizer heatup and cooldown rates and auxiliary spray water temperature differential are provided ,

to assure that the pressurizer is operated within the design criteria assumed for the fatigue analysis performed in accordance with the ASME Code requirements. ,

Pressure-temperature limit curves shown in figure B 3/4 4-3 were developed for the limiting ferritic steel component within an isolated reactor coolant loop. The limiting component is the steam generator channel head to tubenheet region. This figure provides the ASME III, Appendix G limiting curve which is used to define operational bounds, such that when operating with an isolated loop the analyzed pressure-temperature limits are known. The temperature range provided bounds the expected operating range for an isolated loop. ,

OVERPRESSURE PROTECTION SYSTEMS BACKGROUNQ j The overpressure protection system (OPPS) controls RCS pressure at l low temperatures so the integrity of the reactor coolant pressure '

boundary (RCPB). is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G. The reactor vessel 'is the limiting RCPB component for demonstrating such protection. The maximum setpoint for the power operated relief (PORVs) and the maximum RCS pressure for the existing RCS cold valves l leg temperature during cooldown, shutdown, and heatup meet the 10 CFR I 50, Appendix G requirements during the OPPS MODES. l The reactor vessel material is less tough at low temperatures than at normal operating temperature. As the vessel neutron exposure ;

accumulates, the material toughness decreases and becomes less l resistant to pressure stress at low temperatures. RCS pressure, I therefore, is maintained low at low temperatures and is increased only as temperature is increased.

BEAVER VALLEY - UNIT 2 B 3/4 4-14 Amendment No.

(Proposed Wording) l

NPF-73 REACTOR COOLAllT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

BACKGROUND (Continued)

The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only during shutdown; a pressure fluctuation can occur more quickly than an operator can react to relieve the condition. Exceeding the RCS P/T limits by a significant amount ecvid cause brittle cracking of the reactor vessel. LCO 3.4.9.1, "Pacasure/ Temperature Limits," requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the limits.

This LCO provides RCS overpressure protection by having a minimum coolant input capability and having adequate pressure relief capacity. Limiting coolant input capability requires deactivating all but one charging pump and isolating the accumulators. The pressure relief capacity requirec 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 device that acts to terminate an increasing pressure event.

With minimum coolant input capability, the ability to provide core coolant addition is restricted. The LCO does not require the makeup control system deactivated or the safety injection (SI) actuation circuits blocked. Due to the lower pressures in the OPPS MODES and the expected core decay heat levels, the makeup system can provide adequate flow via the makeup control valve and, if needed, until the charging pump is actuated by SI.

The OPPS for pressure relief consists of two PORVs with reduced lift settings or a depressurized RCS and an RCS vent of sufficient size. Two RCS relief valves are required for redundancy. One RCS relief valve has adequate relieving capability to keep from overpressurization for the required coolant input capability.

PORV REOUIREMENTS As designed for the OPPS System, each PORV is signaled-to open if the RCS pressure approaches a limit determined by the OPPS actuation logic. The OPPS actuation logic monitors both RCS temperature and RCS pressure and determines when a condition not acceptable in the limits is approached. The wide range RCS temperature indications are auctioneered to select the lowest temperature signal. The lowest temperature signal is processed through a function generator that calculates a pressure limit for that temperature. The calculated pressure limit is then compared with the indicated RCS pressure from BEAVER VALLEY - UNIT 2 B 3/4 4-15 Amendment No. l (Proposed Wording)

1 1

NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) j 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

PORV REOUIREMENTS (Continued) ;

l a wide range pressure channel. If the indicated pressure meets or exceeds the calculated value, a PORV is signaled to open. Having the i setpoints of both valves within the limits ensures that the Appendix G limits will not be exceeded in any analyzed event. When a PORV is opened in an increasing pressure transient, the release of coolant will cause the pressure increase to slow and reverse. As the PORV releases coolant, the RCS pressure decreases'until a reset pressure is reached and the valve is signaled to close. The pressure continues to decrease below the reset pressure as the valve closes.

RCS VENT REOUIREMENTS Once the RCS is depressurized, a vent exposed to the containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the rell'eving requirements of the transient do not exceed the capabilities of the vent. Thus, the vent path must be capable of relieving the flow resulting from the limiting OPPS mass or heat input transient, and maintaining pressure below the P/T limits. The required vent capacity mty be provided by one or more vent paths.

For an RCS vent to meet the flow capacity requirement, it may be satisfied by removing a pressurizer safety valve or establishing an opening between the RCS and the containment atmosphere of the required size through any positive means available which cannot be inadvertently defeated. The vent path (s) must be above the level of reactor coolant, so as not to drain the RCS when open.

APPLICABLE SAFETY ANALYSES Safety analyses demonstrate that the reactor vessel is adequately protected against exceeding the P/T limits when low RCS temperature conditions exist. At about the enable temperature and below, overpressure prevention is provided by two OPERABLE RCS relief valves or a depressurized RCS and a sufficient sized RCS vent.

The actual temperature at which .the pressure in the P/T limit curve falls below the OPPS setpoint increases as the reactor vessel material toughness decreases due to neutron embrittlement. Each time the heatup and cooldown curves are revised, the OPPS must be re-evaluated to ensure its functional requirements can still be met.

l t

BEAVER VALLEY - UNIT 2 B 3/4 4-15a Amendment No. l (Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

APPLICABLE SAFETY ANALYSES (Continued)

The heatup and cooldown curves represent the Appendix G limits that define OPPS operation. Any change to the RCS that may affect OPPS operation must be evaluated against the analyses to determine the impact of the change on the OPPS acceptance limits.

Transients that are capable of overpressurizing the RCS are categorized as either mass or heat input transients, examples of which follow:

MASS INPUT TYPE TRANSIENTS

a. Inadvertent safety injection; or

b. Charging / letdown flow mismatch. ,

HEAT INPUT TYPE TRANSIENTS

a. Inadvertent actuation of pressurizer heaters;

b. Loss of RHR cooling; or

c. Reactor coolant pump (RCP) startup with temperature asymmetry within the RCS or between the RCS and steam generators.

The following are required during the OPPS MODES to ensure that mass and heat input transients do not occur, which either of the OPPS overpressure protection means cannot handle:

a. Deactivating all but one charging pump OPERABLE;

b. Deactivating the accumulator discharge isolation valves in their closed positions; and

c. Disallowing start of an RCP if secondary temperature is more than 50*F above primary LCO 3.4.1.6, " Reactor Coolant temperature in any one Pump Startup," loop. . this provides protection.

l l

l BEAVER VALLEY - UNIT 2 B 3/4 4-15b Amendment No. l (Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

HEAT INPUT TYPE TRANSIENTS) (Continued)

The analyses demonstrate that either one RCS relief valve or the depressurized RCS and RCS vent can maintain the RCS pressure below the limits when only one charging pump is actuated by SI. Thus, the LCO allows only one charging pump OPERABLE during the OPPS MODES.

Since neither one RCS relief valve nor the RCS vent can handle a full SI actuation, the LCO also requires the accumulators isolated.

The isolated accumulators must have their discharge valves closed and power removed. Fracture mechanics analyses established the temperature of OPPS Applicability at the enable temperature.

PORV PERFORMANCE The fracture mechanics analyses show thAt the vessel is protected when the PORVs are set to open at or below the limit. The setpoint is derived by analyses that model the performance of the OPPS assuming the limiting transient of SI actuation of one charging pump. These analyses consider pressure overshoot and undershoot beyond the PORV opening and closing, resulting from gignal processing and valve stroke times. The PORV setpoints at er below the derived limit ensures the P/T limits will be met.

The Maximum Allowed PORV Setpoint for the OPPS is derived by analysis which models the performance of the OPPS assuming various mass input and heat input transients. Operation with a PORV setpoint less than or equal to the maximum setpoint ensures that Appendix G limits will not be violated with consideration for: (1) a maximum pressure overshoot beyond the PORV setpoint which can occur as'a result of time delays in signal processing and valve opening; (2) a 50*F heat transport effect made possible by the geometrical relationship of the RHR suction line and the RCS wide range temperature indicator used for OPPS; (3) instrument uncertainties; and (4) single failure.

The PORV setpoint will be updated when the revised P/T limits conflict with the OPPS analysis limits. The P/T limits are periodically modified as- the reactor vessel material toughness decreases due to neutron embrittlement caused by neutron Arradiation. Revised limits are determined using neutron fluence projections and the results of examinations of the reactor vessel material irradiation surveillance specimens. The Bases for LCO 3.4.9.1, " Pressure / Temperature Limits," discuss these examinations.

DEAVER VALLEY - UNIT 2 B 3/4 4-15c Amendment No. I (Proposea Wording)

m NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

PORV PERFORMANCE (Continued)

The PORVs are considered active components. Thus, the failure of one PORV is assumed to represent the worst case, single active failure.

RCS VENT PERFORMANCE With the RCS depressurized, analyses show that a PORV or equivalent opening with a vent size of 3.14 square inches is capable of mitigating the allowed OPPS overpressure transient. The capacity of a vent this size is greater than the flow of the limiting transient for the OPPS configuration, SI actuation with one charging pump OPERABLE, mTintaining RCS pressure less than the maximum pressure on the P/T limit curve.

The RCS vent size is based on the PORV' size, therefore, the vent is bounded by the PORV analyses.

The RCS vent is passive and is not subject to active failure.

IS_Q This LCO requires that the OPPS is OPERABLE. The OPPS is OPERABLE when the minimum coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the limits as a result of an operational transient.

To limit the coolant input capability, the LCO requires one charging pump capable of injecting into the RCS and all accumulator discharge isolation valves closed and immobilized. The LCO is qualified by a note that permits two pumps capable of RCS injection for less than or equal to 15 minutes to allow for pump swaps. This note also allows all charging pumps capable of injecting into_the RCS during a change from MODE 3 to MODE 4 to be OPERABLE for a limited period of time.

The LCO is also qualified by a note stating that' accumulator isolation with power removed from the discharge isolation valves is only required when the accumulator pressure is greater than or at the l maximum RCS pressure for the existing temperature, as allowed by the !

P/T limit curves. This note permits the accumulator discharge I isolation valve surveillance to be performed only under these i pressure and temperature conditions. I l

BEAVER VALLEY - UNIT 2 B 3/4 4-15d Amendment No. l (Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

LQQ (Continued)

Operation above 350*F but less than 375'F with only one centrifugal charging pump OPERABLE is allowed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . As shown by analysis, LOCAs occurring at low temperature, low pressure conditions can be successfully mitigated by the operation of a single centrifugal charging pump and a single LHSI pump with no credit for accumulator injection. Given the short time duration that the condition of having only one centrifugal charging pump OPERABLE is allowed and the probability of a LOCA occurring during this time, the failure of the single centrifugal charging pump is not assumed.

Operation below 350*F but greater than 325'F with all centrifugal charging pumps OPERABLE is allowed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months immediately following a change from MODE 3 to MODE 4. This provides a reasonable period of time for the cperators to secure gn OPERABLE pump following entry into MODE 4. Since the charging pump is required to be OPERABLE in MODE 3, but is not required in MODE 4 due to OPPS limitations, some time constraints for making the transition must be identified. During low pressure, low temperature operation, all automatic Safety Injection actuation signals are blocked. In normal conditions, a single failure of the ESF actuation circuitry will result in the starting of at most one train of Safety Injection (one centrifugal charging pump, and one LHSI pump). For temperatures above 325'F, an overpressure event occurring as a result of starting these two pumps can be successfully mitigated by operation of both PORVs without exceeding Appendix G limits. Given the short time duration that this condition is allowed and the low probability of a single failure causing an overpressure event during this time, the single failure of a PORV is not assumed. Initiation of both trains of Safety Injection during this 4-hour time frame due to operator error or a single failure occurring during testing of a redundant channel are not considered to be credible accidents.

The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:

a. Two OPERABLE PORVs; a PORV is OPERABLE for OPPS when its block valve is open, its lift setpoint is set to the limit and testing proves its ability to open at this setpoint, and motive power is available to the two valves and their i control circuits; or

b. A depressurized RCS and an RCS vent.

BEAVER VALLEY - UNIT 2 B 3/4 4-15e Amendment No. I (Proposed Wording)

l 1

NPF-73 )

REACTOR COOLANT SYSTEM l l

BASES (Continued) !

l 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

LCQ (Continued)

An RCS vent is OPERABLE when open with an area of 3.14 square inches. ;

Each of these methods of overpressure prevention is capable of mitigating the limiting OPPS transient.

APPLICABILITY l This LCO is applicable in MODE 4 when any RCS cold leg temperature is less than or equal to the enable temperature, in MODE 5, and in MODE 6 when the reactor vessel head is on. When the reactor vessel head is off, overpressurization cannot occur.

Low temperature overpressure prevention is mo.9t critical during l shutdown when the RCS is water solid, 'and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event.

ACTION

a. With two or more charging pumps capable of injecting into the RCS, RCS overpressurization is possible.

To immediately initiate action to restore restricted coolant input capability to the RCS reflects the urgency of removing ;

the RCS from this condition. l 1

b. An unisolated accumulator requires isolation within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . !

This is only required when the accumulator pressure is at or j more than the maximum RCS pressure for the existing -

temperature allowed by the P/T limit curves.

If isolation is needed and cannot be accomplished in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the ACTION provides two options, either of which must be performed in the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . By increasing the RCS temperature to more than the enable temperature, the .

accumulator pressure cannot exceed the OPPS limits if the l accumulators are fully injected. Depressurizing the accumulators below the OPPS limit also gives this !

protection.

The completion times are based on operating experience that these activities can be accomplished in these time periods indicating that an event requiring OPPS is not likely in the allowed times.

BEAVER VALLEY - UNIT 2 B 3/4 4-15f Amendment No. l (Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

ACTION (Continued)

c. In MODE 4 when any RCS cold leg temperature is less than or equal to the enable temperature, with one required RCS relief valve inoperable, the RCS relief valve must be restored to OPERABLE status within a completion time of 7 days. Two RCS relief valves are required to provide low r

temperature overpressure mitigation while withstanding a single failure of an active component. The exception to Specification 3.0.4 will permit plant heatup with one inoperable PORV. Continued operation is permitted with one PORV inoperable.

The completion time considers the facts that only one of the RCS relief valves is required to mitigate an overpressure transient and that the likelihood of an active failure of the remaining valve path during' this time period is very low. If plant operation results in transitioning to MODE 5, the completion time to restore an inoperable PORV may not exceed 7 days as required by this ACTION.

d. The consequences of operational events that will overpressurize the RCS are more severe at lower temperature. Thus, with one of the two RCS relief valves inoperable in MODE 5 or in MODE 6 with the head on, the completion time to restore two valves to OPERABLE status is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The completion time represents a reasonable time to investigate and repair several types of relief valve failures without exposure to a lengthy period with only one OPERABLE RCS relief valve to protect against overpressure events. If a PORV is inoperable when the plant enters MODE 5 from MODE 4, the completion time to restore an inoperable PORV changes to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months but the cumulative inoperable time may not exceed 7 days before taking action to depressurize and vent.

e. The RCS must be depressurized and a vent must be established within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when both required RCS relief valves are inoperable. The vent must be sized greater than or equal to 3.14 square inches to ensure that the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES. This action is needed to protect the RCPB from a low temperature overpressure event and a possible brittle failure of the reactor vessel.

BEAVER VALLEY - UNIT 2 B 3/4 4-15g Amendment No. 1 (Proposed Wording)

NPF-73 l REACTOR COOLANT SYSTEM I BASES (Continued) 3/4.4.9 PRESSURE / TEMPERATURE LIMITS (ContinuedL ACTION (Continued)

The completion time considers the time required to place the plant in this condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements.

SURVEILLANCE REOUIREMENTS (SR)

SR 4.4.9.3.1 To minimize the potential for a low temperature overpressure event by limiting the mass input capability, a maximum of one charging pump is OPERABLE with the others verified deactivated with power removed and the accumulator disch 4rge isolation valves are verified closed and locked out.

The frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, consideritig other indications and alarms available to the operator in the control room, to verify the required status of the equipment.

SR 4.4.9.3.1.b allows opening the accumulator discharge isolation valves to perform accumulator discharge check valve testing.

SR 4.4.9.3.2 The PORV block valve must be verified open every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to provide the flow path for each required PORV to perform its function when actuated. The valve must be remotely verified open in the main control room. This surveillance is performed if the PORV satisfies the LCO.

The block valve is a remotely controlled, motor operated valvo.

The power to the valve operator is not required removed, and the manual operator is not required locked in the inactive position.

Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months frequency is considered adequate in view of other administrative controls available to the operator in the control room, such as valve position indication, that verify that the PORV block valve remains open.

BEAVER VALLEY - UNIT 2 B 3/4 4-15h Amendment No. l (Proposed Wording)

l NPF-73 !

REACTOR COOLANT SYSTEM !

BASES (Continued) j I

3/4.4.9 PRESSURE / TEMPERATURE LIMITS (Continued)

SURVEILLANCE REOUIREMENTS (SRL (Continued)

The SR is required to be performed prior to entering the condition for the OPPS to be OPERABLE. This assures low temperature overpressure protection is available when the RCS cold leg !

temperature is less than or equal to the enable temperature. l Performing the surveillance every 31 days on each required PORV '

permits verification and adjustment, if necessary, of its lift setpoint, and considers instrumentation reliability which has been 1 shown through operating experience to be acceptable. The CHANNEL FUNCTIONAL TEST will verify the setpoint is within the allowed maximum limits. PORV actuation could depressurize the RCS and is not required.

Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 gonths to adjust the whole channel so that it responds and the valve opens within the required range and accuracy to known input.

SR 4.4.9.3.3 ;

1 The RCS vent of greater than or equal to 3.14 square inches is l proven OPERABLE by verifying its open condition either:

a. Once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for an open vent or valve that cannot be locked, except

b. Once every 31 days for a valve that is locked, or provided l with remote position indication, or sealed, or secured in 1 position. A removed pressurizer safety valve fits this category.

The passive vent arrangement must only be open to be OPERABLE.

This surveillance is required to be performed if the vent is being used to satisfy the pressure relief requirements of the LCO. l I

3/4.4.10 STRUCTURAL INTEGRITY The inservice inspection and testing programs for ASME Code Class 1, 2 and 3 components ensure that the structural integrity and operational readiness of these components will be maintained at an i acceptable level throughout the life of the plant. These programs are l in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR Part 50.55a(g) except where specific written relief has been granted by the Commission pursuant to 10 CFR Part 50.55a (g) (6) (1) .

BEAVER VALLEY - UNIT 2 B 3/4 4-151 Amendment No. l (Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM BASES 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES DACKGROUND The Pressurizer is equipped with two types of devices for pressure relief: pressurizer safety valves and PORVs. The PORVs are electro-solenoid actuated valves that are controlled to open in response to a signal from a pressure sensing system when the pressurizer pressure increases and close when the pressurizer pressure decreases. The PORVs may also be manually operated from the control room.

Block valves, which are normally open, are located between the pressurizer and the PORVs. The block valves are used to isolate the PORVs in case of excessive leakage or a stuck open PORV. Block valve closure is accomplished manually using controls in the control room.

A stuck open PORV is, in effect, a small break loss of coolant accident (LOCA). As such, block valve closure terminates the RCS depressurization and coolant inventory loss.*

The PORVs and their associated block valves may be used by plant operators to depressurize the RCS to recover from certain transients if normal pressurizer spray is not available. Additionally, the series arrangement of the PORVs and their block valves permit performance of certain surveillances on the valves during power operation.

The PORVs may also be used for feed and bleed core cooling in the case of multiple equipment failure events that are not within the design basis, such as a total loss of feedwater.

The PORVs, their block valves, and their controls are powered from emergency power sources in the event of a loss of offsite power. Two PORVs and their associated block valves are powered from two separate safety trains.

The plant has three PORVs, each having a relief capacity of 210,000 lb/hr at 2350 psig. The functional design of the PORVs is based on maintaining pressure below the high pressure reactor trip setpoint. In addition, the PORVs minimize challenges to the pressurizer safety valves and also may be used for low temperature overpressure protection (OPPS). See LCO 3.4.9.3, " Overpressure Protection System."

BEAVER VALLEY - UNIT 2 B 3/4 4-16 Amendment No.

(Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES (Continued)

APPLICABLE SAFETY ANALYSES Plant operators employ the PORVs to depressurize the RCS in response to certain plant transients if normal pressurizer spray is not available. For the Steam Generator Tube Rupture (SGTR) event, the safety analysis assumes that manual operator actions are required to mitigate the event. A loss of offsite power is assumed to accompany the event, and thus, normal pressurizer spray is unavailable to reduce RCS pressure. The PORVs are assumed to be i. sed for RCS depressurization, which is one of the steps performed to equalize the primary and secondary pressures in order to terminate the primary to secondary break flow and the radioactive releases from the affected steam generator.

The PORVs are used in safety analyses for events that result in increasing RCS pressure for which departure from nucleate boiling ratio (DNBR) criteria are critical. Ce'rtain analyses have been performed to study the effects on primary pressure assuming PORV actuation. The results of the turbine trip event. indicate the primary pressure remains within the design limits and the DNBR is maintained within the acceptance criteria.

ISD The LCO requires the PORVs and their associated block valves to be OPERABLE for manual operation to mitigate the effects associated with an SGTR.

By maintaining at least two PORVs and their associated block valves OPERABLE, redundancy has been provided. The block valves are available to isolate the flow path through either a failed open PORV or a PORV with excessive leakage. Satisfying the LCO helps minimize challenges to fission product barriers.

APPLICABILITY In MODES 1, 2, and 3, the PORV and its block valve are required to be OPERABLE to limit the potential for a small break LOCA through the flow path. The most likely cause for a PORV small break LOCA is a result of a pressure increase transient that causes the PORV to open. Imbalances in the energy output of the core and heat removal by the secondary system can cause the RCS pressure to increase to the BEAVER VALLEY - UNIT 2 B 3/4 4-16a Amendment No. l (Proposed Wording)

NPF-73 REACTOR COOLAFT SYSTEM BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES (Continued)

APPLICABILITY (Continued) l PORV opening setpoint. The most rapid increases will occur at the higher operating power and pressure conditions of MODES 1 and 2. The PORVs are also required to be OPERABLE in MODES 1, 2, and 3 to minimize challenges to the pressurizer safety valves.

Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. Therefore, the LCO is applicable in MODES 1, 2, and 3. The LCO is not applicable in MODE 4 when both pressure and core energy are decreased and the pressure surges become much less significant. The PORV setpoint is reduced for OPPS in MODES 4 (below the enable temperature), 5, and 6 with the reactor vessel head in place. LCO 3.4.9.3 addresses the PORV requirements in these MODES.

ACTION A General Note provides clarification that all pressurizer PORVs and block valves are treated as separate entities, each with separate completion times (i.e., the completion time is on a component basis).

a. With one PORV inoperable, either the PORV must be restored or the flow path isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The block valve should be closed with power removed from the associated block valve because of downstream piping concerns. With the block valve closed, the potential exists to condense steam in the piping between the block valve and the downstream PORV. If the block valve were opened and the PORV actuated, the piping downstream of the PORV may be overstressed due to the slug of water being forced down the piping. Based on the downstream piping concern, it is prudent to remove power from the closed block valve. Removing power from the block valve renders the block valve inoperable, however, two PORVs and their associated block valves remain OPERABLE and redundancy exists for PORV operation. Therefore, plant operation may continue with one block valve closed and power removed. PORV inoperability may be due to seat leakage, instrumentation problems (including PORV accident monitoring instruments identified in LCO 3.3.3.8), or other causes.

Automatic control problems and related instrumentation problems would not render the PORVs inoperable. Accident analyses assume manual operation of the PORVs and do not take credit for automatic actuation. This condition is only intended to permit operation of the plant for a limited BEAVER VALLEY - UNIT 2 B 3/4 4-16b Amendment No. l (Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES (Continued)

ACTION (Continued) period of time not to exceed the next refueling outage so that maintenance can be performed on the PORV to return the valve to an OPERABLE condition. Normally, the PORV should be available for automatic mitigation of overpressure events and should be returned to OPERABLE status prior to entering startup (MODE 2).

The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is based on plant operating experience that has shown that minor problems can be corrected or closure accomplished in this time period.

b. With two PORVs inoperable, they must be either restored or isolated by closing the associated block valves and removing the power to the associated block valves. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, b'ased on challenges to the PORVs during this time period, and provides the operator adequate time to correct the situation. If the inoperable valves cannot be restored to OPERABLE status, the inoperable valves must be isolated within the specified time. Because there is one PORV that remains OPERABLE, an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is provided to restore at least one inoperable PORV to OPERABLE status. If a PORV cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply.

c. If three PORVs are inoperable, it is necessary to either restore at least one valve within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or isolate the flow path by closing and removing the power to the associated block valves. The completion time of 1 hour is reasonable, based on the small potential for challenges to the system during this time and provides the operator time to correct the situation. If one PORV is restored, then the plant will be in a less limiting ACTION statement with the time clock started at the original declaration of having three PORVs inoperable. If no PORVs are restored within the completion time, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed completion times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant Uystems. In MODES 4 and 5, maintaining PORV OPERABILITY may be required. See LCO 3.4.9.3.

BEAVER VALLEY - UNIT 2 B 3/4 4-16c Amendment No. l (Proposed Wording)

NPF-73 REACTOR COOLANT SYSTEM l

BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES (Continued) l ACTION (Continued) '

d. If one block valve is inoperable and open, then it is necessary to either restore the block valve to OPERABLE status within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or place the associated PORV in manual control. The prime importance for the capability to close the block valve is to isolate a stuck open PORV. Therefore, if the block valve cannot be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the required action is to place the PORV in manual control to preclude its automatic opening for an overpressure event and to avoid the potential for a stuck open PORV at a time that the block valve is inoperable. If the block valve is inoperable, it is necessary to restore the block valve to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or close it. If block valve instrumentation related to accident monitoring instrumentation identified in LCO 3.3.3.8 is determined to be inoperable, then the block valve shall be declared inoperable. Closing the block valve precludes the need to place the PORV in manual control since it is isolated from the system. The completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is reasonable, based on the small potential for challenges to the system during this time period, and provides the operator time to correct the situation.

Because at least one PORV remains OPERABLE, the operator is permitted a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore the inoperable open block valve to OPERABLE status.- If it cannot be restored within this additional time, the plant must be brought to a MODE in which the LCO does not apply in order to avoid continuous operation without a redundant ability to isolate this PORV flow path. If the block valve is restored within the completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , the power will be restored and the PORV restored to OPERABLE status. With one block valve inoperable and closed, there still remains two PORV flow paths. This redundancy will allow continued operation until the next refueling outage to perform maintenance on the inoperable valve and return it to OPERABLE status.

e. If more than one block valve is inoperable, it is necessary to either restore the block valves within the completion time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , or place the associated PORVs in manual control and restore at least one block valve within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

[and restore a minimum of two block valves within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ). Two OPERABLE PORVs provide redundancy to allow continued operation until the next refueling outage to perform maintenance on the inoperable valve and return it to BEAVER VALLEY - UNIT 2 B 3/4 4-16d Amendment No. l (Proposed Wording)

NPF-73 EEACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES (Continued)

ACTION (Continued)

OPERABLE status. The completion times are reasonable, based on the small potential for challenges to the system during this time and provide the operator time to correct the situation. If the required actions are not met, then the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed comple. tion times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODES 4 and 5, maintaining PORV OPERABILITY may be required. See LCO 3.4.9.3.

i SURVEILLANCE REOUIREMENTS (SR)

SR 4.4.11.1 This surveillance requires a complete cycle of each PORV.

Operating a PORV through one complete cycle ensures that the PORV can be manually actuated for mitigation of an SGTR. The frequency of 18 months is based on a typical refueling cycle and industry accepted practice.

SR 4.4.11.2 Block valve cycling verifies that tom valve (s) can be closed if needed. The basis for the frequency t' 92 days is the ASME Code,Section XI. If the block valves are closed to isolate inoperable PORVs, the maximum completion time to restore one PORV and open the block valve is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , which is well within the allowable limits (25%) to extend the block valve frequency of 92 days. Furthermore, these test requirements would be completed by the reopening of a recently closed block valve upon restoration of the PORV to OPERABLE status (i.e., completion of the required actions fulfills the SR).

This SR is not required to be met with the block valve closed, in accordance with required ACTIONS a, b, or c of this LCO.

BEAVER VALLEY - UNIT 2 B 3/4 4-16e Amendment No. l (Proposed Wording)

i NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4 4.12 REACTOR COOLANT SYSTEM HEAD VENTS Reactor Coolant System Vents are provided noncondensable gases to exhaust and/or steam from the primary system that could.

inhibit ' natural circulation core cooling. The OPERABILITY of at least one reactor coolant systen vent path from the reactor vessel head or the pressurizer steam space via exists to perform this function. the PORV's ensures the capability l

The valve redundancy of the Reactor Coolant Systen Head vent I paths serves to minimize the probability of inadvertent or i

, irreversible actuation while ensuring that a single failure of a vent valve, power supply or control system does not prevent isolation of the vent path.

The function, capabilities, and testing requirements of the Reactor Coolant Systen vent systems are consistent with. the requirements of Item II.B.1 of NUREG-0737, Action Plan Requirements," November 1980. "Clarificat on of TMI BEAVER VALLEY - UNIT 2 B 3/4 4-16f. Amendment No. l (Proposed Wording)

NPF-73 ADMINISTRATIVE CONTROLS SPECIAL REPORTS (Continued)

d. Seismic event analysis, Specification 4.3.3.3.2.

e. Sealed source leakage in excess of limits, Specification 4.7.9.1.3.

f. Miscellaneous reporting requirements specified in the ACTION l Statements for Radiological Effluent Technical Specifications.

g. Containment Inspection Report, Specification 4.6.1.6.2.

h. Steam generator tube inservice inspection, Specification 4.4.5.5.

1. Inoperable accident monitoring, Specification 3.3.3.8. l 6.10 RECORD RETENTION 6.10.1 The following records shall be retai'ned for at least five (5) years;

a. Records and logs of facility operation covering time interval at each power level.

b. Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.

c. All REPORTABLE EVENTS. l

d. Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

o. Records of reactor tests and experiments.

f. Records of changes made to Operating Procedures.

g. Records of radioactive shipments.

h. Records of sealed source leak tests and results,

i. Records of annual physical inventory of all sealed source material of record.

6.10.2 The following records shall be retained for the duration of the Facility Operating License:

a. Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.

BEAVER VALLEY - UNIT 2 6-19 Amendment No.

(Proposed Wording)

1 ATTACHMENT D l

Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 DESCRIPTION OF CHANGES Specification Chance DescriotiRD 3.1.2.3 "At least" is added to the LCO.

Note (1) is added to "one charging pump".

Lower case letters on " Low Head Safety Injection Pump".

ACTION BV-1 replace " charging" with "above".

Lower case letters on " Low Head Safety Injection Pump".

SR 4.1.2.3.2 Moved to Specification 3.4.9.3.

SR 4.1.2.3.3 Renumbered to 4.1.2.3.2.

Lower case letters on " Low Head Safety Injection Pump" (in 4 places).

SR 4.1.2.3.3.d Replaced vent surveilla'nce requirements with reference to SR 4.4.9.3.3.

Nota Deleted, since the new SR 4.4.9.3.1.a does not preclude performing the pump testing addressed in the note.

(1) Note Added to refer to specification 3.4.9.3 for charging pump limitations.

- Note Deleted, the contents of this note are addressed in SR 4.4.9.3.3.

3.1.2.4 Replaced

note with (1), replaced "%" with (BV-2 only) " percent," replaced "2" with " greater than or equal to " the

, in note replaced reference to Specification "4.1.2.3.2" with "3.4.9.3."

3.3.3.8 ACTION a Replaced BV-1 reference to Specification 3.4.11.a with 3.4.11 and for both units modified the exception for the PORVs to clarify the items this action applies to.

BV-1 Added an exception for isolated PORV's same as ACTION b ACTION a exception, only applies to. Table 3.3-11 Item 4 since Items 5 and 6 require zero minimum channels operable.

D-1

I l

ATTACHMENT D )

l Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 i DESCRIPTION OF CHANGES 1

I Specification Chance Descriotion BV-1 Deleted Item 9 "PORV Control Pressure Channels Table 4.3-7 (PT-RC-444, 445)" since these channels are not required to satisfy the accident analysis assumptions.

3.4.9.3 Modified this LCO to specify an operable OPPS along with limiting to 1 the number of charging pumps operable [ includes note (1) to allow 2 operable pumps for 15 minutes for pump swap and for BV-2 allows all pumps operable for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during cooldown from Mode 3 to Mode 4] and the accumulators isolated [ includes note (2) to qualify the accumulator isolation requirements).

AEELICABILITY Modified to specify modes wi,th qualifications.

ACTION a Separated into new ACTIONS "c" and "d" qualified by mode requirements and addresses 1 inoperable PORV with "12" hours to be in a depressurized and vented condition. The new ACTION statement "c" includes a qualifier to clearly apply this ACTION in Mode 4 when any RCS cold leg temperature is less than or equal to the enable temperature. Included exception to Specification 3.0.4, Unit 2 only.

ACTION b Modified as new ACTION "e," maintains "12" hours to be in a depressurized and vented condition and addresses 2 inoperable PORV's.

ACTION c Deleted.

New ACTION a Addresses 2 or more operable charging pumps with "12" hours to be in a depressurized and vented condition.

New ACTION b Addresses non-isolated accumulators.

SR 4.4.9.3. loa Renumbered to 4.4.9.3.2.b.

SR 4.4.9.3.1.b Renumbered to 4.4.9.3.2.c.

SR 4.4.9.3.1.c Renumbered to 4.4.9.3.2.a.

SR 4.4.9.3.1 4 Deleted. I i

i 1

D-2

)

l

ATTACHMENT D Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 DESCRIPTION OF CHANGES Snecification Chance Descrintion ER 4.4.9.3.2 Renumbered to 4.4.9.3.3 and 4.4.9.3.3.a, applicable

note re-annotated to 4.4.9.3.3.b and replaces "7 day" frequency with "31 day" frequency.

3.4.11 BV-1 replaced "(Two)" with "Each".

BV-2 replaced "All" with "Each".

ACTIONS Added a General Note that applies to all ACTION statements. This note is consistent with ISTS Note 1 and states that: Separate Action statement entry is allowed for each PORV and block valve.

ACTION a Replaced by ACTIONS "a", "b" and "c" with additional POR" qualification requirements.

The proposed actions have been modified from the ISTS wording to recognize that two operable PORVs satisfy the redundancy requirer. ants. This allows isolating one inoperable PORV and removing power from the block valve until the next time the plant enters a refueling outage and can repair the valve.

New ACTION a Applies with 1 or more PORV's inoperable but capable of being manually cycled. The BV-2 action differs from the ISTS to address concerns related to ,

overstressing downstream piping. l New ACTION b Applies with 1 or more PORV's inoperable but not I capable of being manually cycled, allows up to 72 i hours in this condition. The ISTS "not capable of !

being manually cycled" is not applicable to BV-2 since any time a block valve is closed the PORV is inoperable.

New ACTION c Applies with 3 PORV's inoperable but not capable of being manually cycled, allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore or close the associated block valves and remove power from the block valves then shutdown. The ISTS "not capable of being manually cycled" is not applicable to BV-2 since any time a block valve is closed the PORV is inoperable.

ACTION b Replaced by ACTIONS "d" and "e" with additional block valve qualification requirements.

D'

ATTACHMENT D Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 DESCRIPTION OF CHANGES Snecification Chance Description New ACTION d Applies with 1 block valve inoperable and open, allows 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to restore or place the associated PORV's in manual control, then allows additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore or shutdown. With 1 block valve inoperable but capable of being closed, then close it, operation can then continue until the next time the plant enters a refueling outage and can repair the valve.

New ACTION e Applies with more than 1 block valve inoperable, allows 1 hour to restore or place the associated PORVs in manual control. Then allows 1 additional hour to restore at least 1 block valve if 3 block valves are inoperable and allows up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to restore at least 2 block val,ves or shutdown.

SR 4.4.11.1 Replaced this surveillance with the ISTS requirement to stroke the PORVs once per 18 months.

SR 4.4.11.2 Modified to provide an exception to the block valve cycle requirements when the block valve is closed to meet the required ACTIONS.

SR 4.4.11 1 Deleted the BV-1 SR since the PORVs and block valves are normally supplied by emergency power sources.

SR 4.5.1.3 Moved to Specification 3.4.9.3 Note (2).

Note Moved to SR 4.4.9.3.1.b.

D-4 l

ATTACHMENT E Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 BV COMPARISON WITH ISTS PROPOSED BV TECH SPEC LEIS 3.1.2.3 CHARGING PUMP-SHUTDOWN This Tech Spec was relocated to another controlled document.

BV-2 3.1.2.4 CHARGING PUMPS-OPERATING This Tech Spec was relocated to another controlled document.

3.3.3.8 ACCIDENT MONITORING 3.3.3 POST ACCIDENT INSTRUMENTATION MONITORING (PAM)

INSTRUMENTATION Proposed exception to Actions "a" The proposed exception to and "b" for the PORVs. Actiqns "a" and "b" for the PORVs is not in the ISTS since the PORVs are not listed in the PAM Table.

[The PORVs will remain in this Spec. since they meet the criteria for inclusion, i.e., "SER for REG. GUIDE 1.97 identifies the PORV position indication as a Non-Type A instrument").

3.4.9.3 is consistent with the ISTS 3.4.12 except for the following.

Note (1) allows 2 operable charging Required Action B.1 note.

pumps for pump swap operation for s 15 minutes and for BV-2 allows all pumps operable for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months during cooldown from Mode 3 to Mode 4.

Note (2) qualifies the accumulator Note following the 1 isolation requirements to maximum Applicability statement 1 RCS pressure for the existing RCS qualifies the accumulator cold leg temperature allowed by isolation requirements to the i the heatup and cooldown curves. maximum RCS cold leg '

temperature allowed by the P/T limit curves provided in the PTLR.

Action "a" includes 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to vent. Conditions "A" and "G" E-1 l

j

ATTACHMENT E Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 BV COMPARISON WITH ISTS EROPOSED BV TECH SPEC ISTS Action "b" Conditions "C", "D" and "G" Action "c" includes 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to vent. Conditions "E" and "G" Action "d" includes 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to vent. Conditions "F" and "G" Action "o" includes 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to vent. Condition "G" No similar Action Condition G "LTOP system inoperable for any reason other than condition A, B, C, D, E, OR F".

This SR only applies to plants SR 3.4.12.1 with HPI pumps, i

SR 4.4.9.3.1.a SR 3.4.12.2 SR 4.4.9.3.1.b also includes the SR 3.4.12.3 contents of the

note moved from SR 4.5.1.3 to allow testing the accumulator discharge check valves.

This SR only applies to plants that SR 3.4.12.4 use RHR suction relief valves for OPPS.

SR 4.4.9.3.2.a SR 3.4.12.6 This SR only applies to plants that SR 3.4.12.7 use RHR suction relief valves for OPPS, SR 4.4.9.3.2.b " COT" in the ISTS has SR 3.4.12.8 been replaced with " CHANNEL FUNCTIONAL TEST" for consistency with current nomenclature and retains the current SR instead of the ISTS wording regarding performance of the " CHANNEL FUNCTIONAL TEST."

SR 4.4.9.3.2.c SR 3.4.12.9 SR 4.4.9.3.3.a SR 3.4.12.5 E-2

ATTACHMENT E Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 BV COMPARISON WITH ISTS PROPOSED DV TECH SPEC IH.TH SR 4.4.9.3.3.b includes current SR 3.4.12.5 description of locked valves.

3.4.11 is consistent with the ISTS 3.4.11 except for the following.

ISTS Note (1) is included in a Note (1) allows separate General Note that allows condition entry for each separate condition entry for PORV and block valve.

each PORV.

This exception has been deleted. Note (2) provides an exception to Spec. 3.0.4.

The proposed actions have been modified from the ISTS wording to i recognize that two operable PORVs satisfy the need for redundancy.

This allows isolating one inoperable PORV and removing power from the block valve until the next time the plant enters a refueling outage to repair the valve.

Action "a" Conditions "A" and "D" i

Action "b" Conditions "B" and "D" l

)

Action "c" Condition "E" Action "d" Conditions "C" and "D" Action "e" Conditions "F" and "G" SR 4.4.11.1 requires cycling the SR 3.4.11.2 and SR 3.4.11.3 PORVs and for BV-1 (only) requires using both the normal air and backup nitrogen supply system.

SR 4.4.11.2 SR 3.4.11.1 SR 4.4.11.3 for BV-1 (only) has SR 3.4.11.4 l been deleted since the PORVs and I block valves are normally supplied by emergency power sources. The BV-2 PORVs and block valves are normally powered from the emergency bus.

E-3

ATTACHMENT F Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 BASES COMPARISON 4

i ISTS 3.4.12 PROPOSED SPECIFICATION 3.4.9.3 Low Temperature Overpresaure The current title Protection (LTOP) System Overpressure Protection 1 System (OPPS) is maintained.

Refers to PTLR. Reference to the PTLR is replaced by reference to the heatup and cooldown curves. l

[275]*F Specifies enable temperature.

PORV Reauirements PORV Reauirements LTOP actuation logic monitors BV-1 OPPS only monitors both RCS temperature and RCS pressure, pressure. ,

The PORV setpoints are normally The BV PORV setpoints are not staggered. staggered.

RCS Vent Reauirements RCS Vent Reauirements For an RCS vent to meet the For an RCS vent to meet the flow capacity requirement, flow capacity requirement, it requires removing a it requires removing a pressurizer safety valve, pressurizer safety valve (removing a PORV's internals, (or establishing an opening and disabling its block valve between the RCS and the in the open position, or containment atmosphere of the similarly establishing a vent required size through any by opening an RCS vent valve), positive means available which cannot be inadvertently defeated.)

Applicable Safety Analyses Applicable Safety Analyses

{

Any change to the RCS must be Any change to the RCS (that evaluated against the analyses may affect OPPS operation) to determine the impact of the must be evaluated against change on the OPPS acceptance the analyses to determine limits. the impact of the change on the OPPS acceptance limits. ;

Heat Input Typ3 Transients Heat Input Type Transients The analyses show the effect We don't have this analysis I of accumulator discharge is so discussion was deleted. l over a narrower range ([175]*F and below) than that of the LCO

([275]*F and below).

I F-1 !

ATTACHMENT F Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 BASES COMPARISON ISTS 3.4.12 PROPOSED SPECIFICATION 3.4.9.3 RCS Vent Performance RCS Vent Performance The RCS vent size will be Replaced with, "The RCS vent re-evaluated each time the P/T size is based on the PORV limit curves are revised based size,therefore, the vent is on the results of the vessel bounded by the PORV material surveillance. analyses." In the ISTS the vent size is different from the PORV size, but at BV the vent size was selected based on the size of the PORV, therefore, the vent is bounded by the PORV analyses.

LC2 IEQ ACTION B.1 note that permits two The LCO is qualified by a pumps capable of RCS injection note that permits two pumps for s 15 minutes to allow capable of RCS injection for pump swap. for 5 15 minutes to allow for pump swap. For BV-2, this note also allows all charging pumps capable of injecting into the RCS during a change from Mode 3 to Mode 4. This is consistent with the contents of current SR 4.1.2.3.2.

Accumulator isolation note The LCO is also qualified is discussed under by a note stating that APPLICABILITY. accumulator isolation is only required when the accumulator pressure is greater than or at the maximum RCS pressure for the existing temperature, as allowed by the P/T limit curves. This note permits the accumulator discharge isolation valve surveillance to be performed only under these pressure and temperature conditions.

RCS vent 2 [2.07] square RCS vent 2 3.14 square inches inches based on analysis. based on PORV size.

F-2

ATTACHMENT F Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 BASES COMPARISON ISTS 3.4.12 PROPOSED SPECIFICATION 3.4.9.3 ACTION G.1 ACTION e The RCS must be depressurized }The intent of this and a vent must be established } discussion is provided in within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months when: } paragraph form, however, the

}0 hours to vent is replaced

a. Both required RCS relief }with 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months valves are inoperable; or }is consistent'with the

} current action vent require-

b. A Required Action and associated }ments and is incorporated in Completion Time of Condition ) ACTIONS a, c, d, and e.

A, B, C, D, E or F is not met; or }

c. The LTOP System is inoperable }NA [not consistent with for any reason other than } current format)

Condition A, B, C, D, E or F. -} ,

SR 3.4._1 M SR 4.4.9.3s h verify a maximum of one charging Verify a maximum of one pump is capable of injecting charging pump is capable of into the RCS. injecting into the RCS.

ER 3.4.12.3 ER_1 4.9.3.1.b Verify each accumulator is isolated. SR 4.4.9.3.1.b also allows opening the accumulator discharge isolation valves to perform accumulator discharge check valve testing. This is consistent with current Spec.

4.5.1.3

note.

F-3

l ATTACHMENT F Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 BASES COMPARISON 1

ISTS 3.4.12 PROPOSED SPECIFICATION 3.4.9.3 SR 3.4.12.8 SR 4.4.9.3.2 Discusses a note applied to this The ISTS SR has been SR indicating this SR is required modified to retain existing to be met 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after decreasing requirements to perform a RCS cold leg temperature $ [275]*F. channel functional test prior to decreasing RCS cold leg temperature to less than or equal to the enable temperature.

SR 3.4.12.2 & SR 3.4.12.3 SR 4.4.9.3.1 SR 3.4.12.5 SR 4.4.9.3.3 SR 3.4.12.6 & SR 3.4.12.8 SR 4.4.9.3.2

& SR 3.4.12.9 ISTS 3.4.11 PROPOSED SPECIFICATION 3.4.11 BACKGROUND BACKGROUND The plant has 2 PORVs. The plant has 3 PORVs.

APPLICABLE SAFETY ANALYSES APPLICABLE SAFETY ANALYSES By assuming PORV manual actuation, Certain analyses have been the primary pressure remains below performed to study the the high pressurizer pressure trip effects on primary pressure setpoint, thus the DNBR calculation assuming PORV actuation. The is more conservative. Events that results of the loss of assume this condition include a external load and/or a turbine trip and the loss of turbine trip event indicate normal feedwater. the primary pressure remains within the design limits and the DNBR is maintained within the acceptance criteria.

[The UFSARs specify PORV actuation for this event but not automatic actuation.]

ACTIONS ACTIONS Note 1 (Separate condition entry A general note is included.

is allowed for each PORV] [ Separate ACTION statement entry is allowed for each PORV and block' valve.]

F-4

ATTACHMENT F Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed Technical Specification Change No. 184 and 49 BASES COMPARISON ISTS 3.4.11 PROPOSED SPECIFICATION 3.4.11 Note 2 [LCO 3.0.4 is not The ISTS actions have been applicable] modified slightly to recognize that two operable PORVs provide redundancy for continued plant operation, therefore, an exception to LCO 3.0.4 is not required.

ACTION A.1, D.1 & D.2 ACTION a ACTION B.1, B.2, B.3, D.1 & D.2 ACTION b ACTION E.1, E.2, E.3 & E.4 ACTION c ACTION C.1, C.2, D.1 &D.2 ACTION d 1

ACTION F.1, F.2, F.3, G.1 & G.2 ACTION e SR 3.4.11.2 and for BV-1 only SR 4.4.11.1 SR 3.4.11.3 SR 3.4.11.1 SR 4.4.11.2 SR 3.4.11.4 For BV-1 only SR 4.4.11.3 has been deleted, this SR is not applicable since both units' PORVs and block valves are powered from emergency sources.

F-5

ML20065M339

Text

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