ML20086B209

Provides Revised No Significant Hazards Evaluation for Proposed TS Change Requests 212 & 78,revising Quadrant Power Tilt Ration Requirements

ML20086B209
Person / Time
Site:	Beaver Valley
Issue date:	06/23/1995
From:	Noonan T DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9507050226
Download: ML20086B209 (6)

Text

5

r ,; ,

v Valley Power Station SNppingport. PA 150U-0004

= ?o

Nuclear Operations

,.i::::=

June 23, 1995 U. S. Nuclear Regulatory Commission  :

Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Response to Letter Dated January 13,1995 This letter is in response to the NRC letter dated Jamlary 13,'1995, and provides a )

revised No Significant Hazards Evaluation for proposed Technical Specification Change l Request Nos. 212 and 78' revising the quadrant power tilt ratio requirements. Attached  :

are revised pages B-7 through B-10 which replace pages B-7 through B-12 in the  !

original submittal dated October 11,1994.  !

I If you have any questions regarding the attached response, please contact Mr.  ;

Nelson Tonet, Manager, Nuclear Safety Department, at (412) 393-5210. l Sincerely, W

Thomas P. Noonan Attachment l l

c: Mr. L. W. Rossbach, Sr. Resident Inspector Mr. T. T. Martin, NRC Region I Administrator  !

Mr. D, S. Brinkman, Sr. Project Manager  ;

J ] .

INM %"

0300.1.3 ENERGV

'607050226 950623 PDR ADOCK 05000334 P PDR

AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA)

). SS:

COUNTY OF BEAVER )

Subject:

Beaver Valley Power Station, Unit No.1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Technical Specification Change Nos. 212 and 78 Before me, the undersigned notary public, in and for the County and Commonwealth aforesaid, this day personally appeared Thomas P. Noonan, to me known, who being duly sworn according to law, deposes and says that he is Division Vice President, Nuclear Operations of the Nuclear Power Division, Duquesne Light Company, he is duly authorized to execute and file the foregoing submittal on behalf of said Company, and the statements set forth in the submittal are true and correct to the best of his knowledge, information and belief.

WkW Thomas P. Noo' nan i

Subscribed and sworn to before me on thisyday of , /7 73 x {>w 0 $bswL

~~

/

l gotaly Pdblic m sa ,

w - % %7 Boro Ek u.ww. - - an.

ATTACHMENT B, continued Proposed Technical Specification Change No. 212 and 78 Page 7 These changes are consistent with the UFSAR design description and analyses assumptions concerning verification of safe core operation. The proposed changes will ensure the core operates within the fuel design criteria and that the power distribution remains within the bounds of the safety analyses, therefore, the proposed changes are considered to be safe and will not reduce

'the safety of the plant.

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

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

(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 existing quadrant power tilt ratio (QPTR) definition and Surveillance Requirement (SR) 4.2.4.c are inconsistent concerning reactor power limitations when performing QPTR surveillance requirements. The proposed change modifies these and related requirements to improve the understanding and consistency by generally incorporating the Improved Standard Technical Specification .(ISTS) requirements of NUREG-1431.

Editorial changes have been incorporated throughout the proposed specifications to address ISTS or plant specific convention and do not affect the accident analyses. The QPTR definition has been modified to reflect the ISTS wording and eliminate the inconsistency with SR 4.2.4.c.

This change does not reduce the QPTR testing requirements B-7

l ATTACHMENT B, continu0d Proposed Technical Specification Change No. 212 and 78 l Page 8 -

1 or affect the accident analyses assumptions. The current-action statements require ~ power reduction along with a reduction in power range high neutron flux trip setpoints when the QPTR exceeds the limit. This ensures the core conditions are consistent with the accident analyses assumptions. With the modified action statements and the-QPTR exceeding the limit, power reduction is also required along with performing a flux map to verify the peaking factors are within the accident analyses assumptions. In addition, the safety analyses must be re-evaluated to confirm the results remain valid prior to increasing power with an indicated tilt condition. The new action statements provide methods different from the current requirements.

However, they satisfy the same objective, to ensure the conditions assumed in the accident analyses are maintained.

Therefore, these changes will not involve significant increase in the probability or consequences of an accident previously evaluated.

The current surveillance requirements define-the methods and frequencies for verifying the QPTR is within the limit specified in the limiting condition for operation. The proposed SRs include associated notes that allow separation of a power range channel into two portions made-up of the Nuclear Instrumentation System (NIS) and the excore detector portion. If an excore detector portion of a power range channel is inoperable, then the power range channel is ,

inoperable since the detector provides input to the NIS which inputs to the solid state protection system. However, if the excore detector is operable and the NIS is inoperable, then the power range channel is inoperable but the ability to monitor the QPTR is unaffected. When the NIS portion of a channel is inoperable, appropriate actions are applied in accordance with specification 3.3.1. The new SRs continue to require the same testing and frequencies as the i current SRs along with reducing the need to interpret the l requirements when special conditions exist. Therefore, the l proposed SRs will not affect the accident analyses or significantly increase the probability or consequences of an ,

accident previously evaluated. j Table 3.3-1 Action 2 applies when a power range channel is l inoperable. This action has been reformatted to incorporate j changes similar to those adopted in the QPTR SR which allow l separation of a power range channel into the NIS portion and I the excore detector portion. Proposed Action 2.a applies to an inoperable power range high neutron flux channel and Action 2.b applies to "all other channels" which includes l the Low Setpoint function along with the High Positive and l High Negative Rate functions. The new action is modified by l Note (3) to allow bypassing the inoperable channel for surveillance testing and setpoint adjustment and by Note (4)

B-8

I t.

ATTACHMENT B, continued l Proposed Technical Specification Change No. 212 and 78 j Page 9 '

that only requires performing SR 4.2.4 when the power range high neutron flux channel input to QPTR is inoperable. The new action does not require reducing the power range neutron flux setpoint_ like the current action since the proposed action is to perform the QPTR surveillance or shutdown which is more conservative than the current action requirement, otherwise, the new action requires essentially the same steps to be performed as the current action. Therefore, the proposed action will not affect the accident analyses or involve a significant increase in tite probability or consequences of an accident previously evaluated.

These changes are proposed to allow flexibility in plant operations by modifying the QPTR action and surveillance requirements to allow separation of a power range channel into the NIS portion and the excore detector portion. The ;

modified action and surveillance requirements continue to provide monitoring of those parameters required to ensure the core is operating safely. Since these changes are not significantly different from the current requirements and no change is being introduced that would affect the accident analyses assumptions, we have concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

The proposed changes incorporate modifications generally consistent with the ISTS QPTR requirements to ensure the core power distribution is adequately monitored. The revised action statements provide for peaking factor verification as a logical compensatory measure to ensure the core is operating within required limits. This is more.

conservative than the current requirements and provides  :

additional assurance that Specification 3.2.4 will continue l to govern the QPTR limitations in a manner consistent with the accident analyses assumptions. The revised SR provides clear and understandable testing requirements to reduce confusion concerning how the QPTR is to be monitored based on plant conditions. The proposed change does not introduce any new mode of plant operation or require any physical modification to the plant, therefore, this change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the change involve a significant reduction in a margin  !

of safety?

The QPTR limit ensures that the gross radial power distribution is maintained within the assumptions used in the safety analyses. The QPTR is one of the variables that j B-9

c. .

ATTACHMENT B, continu:d Proposed Technical specification Change No. 212 and 78 Page 10,'

is monitored to ensure the core operates within the bounds used in the safety analyses. When the QPTR is maintained below 1.02 it provides an indication that the peaking factors are within the limiting values by preventing an undetected change in the gross radial power distribution.

The- proposed changes ensure the required parameters are verified during the applicable conditions and on a consistent basis, therefore, these changes will not reduce the margin of safety.

F. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the above safety analysis, 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.

B-10