Text

Proposed TS 3.4.11 Actions,Sr & Bases to Better Reflect Combination of Guidance in NUREG-1431 & Existing Unit 1 TS Requirements
	ML20086R934
Person / Time
Site:	Beaver Valley
Issue date:	07/24/1995
From:	; DUQUESNE LIGHT CO.
To:	;
Shared Package
ML20086R926	List: ML20086R923; ML20086R934;
References
	RTR-NUREG-1431 NUDOCS 9508010043
	Download: ML20086R934 (20)
	v • d • e

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e NPF-73 REACTOR COOLANT SYSTEM 3/4.4.11 DFLTEF VALVES :

LIMITING CONDITION FOR OPERATION f i

3.4.11 Each jd>wer-derated [elief [alve (PORV) and associated i block valve shall be OPERABLE. .

i APPLICABILITY: MODES 1, 2, and 3. I e

ACTION:

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

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

I

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 i PORV to OPERABLE status or close the associated block valva l and remove power from the block valve; otherwise, be in at [

1 east HCfr 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. l

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 i and remove power from the block valves; restore at least one l

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 i 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 / aM nar cajkth/e ot~ Aci

Mn u ally cycled ,

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 I !

least one PORV to OPERABLE status or close the associated )

block valves and remove power from the block valves and be in i 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 l within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

f 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 I either restore the block valve to OPERABLE status or place

[684ME the associated PORV in manual control. Restore the block gj7j/ 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 X#56 W / 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.

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l BEAVER VALLEY - UNIT 2 3/4 4-39 Amendment No.

'Droposed Wording) l 9508010043 950724 PDR ADOCK 05000412 P PDR

INSERT 1

a. With one or more PORVs inoperable and capable of being manually cycled, OPERABLE status or within i hour either restore the PORV(s) to ,

power maintained to close the associated block valve (s) with the block valve (s); otherwise, be in at l

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 {

sanually 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 remove power associated block valves and I from the block valve (s); a minimum of two PORVs i 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 NOT l 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 I the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . With one PoRV inoperable and l isolated, power operation may continue until the next refueling outage. l

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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 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.

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

@ g or c. l 1

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4 i BEAVER VALLEY - UNIT 2 3/4 4-39a Amendment No.

(Proposed Wording) l

NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RFLIEF VALVES (Continued)

APPLICABILITY (Continued)

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.

i Pressure increases are less prominent in MODE 3 because the core input energy is reduced, but the RCS pressure is high. Therefore, i 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 l 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.

1 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).

( [ With one PORV inoperable, either the PORV mu 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 i in the piping between the block valve and the downstream i PORV. If the block valve were opened and the PORV actuated, I the piping downstream of the PORV may be overstressed due to the slug of water being forced down the piping. Based on I 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 fE/24cE take credit for automatic actuation. This condition is only g/g intended to permit operation of the plant for a limited, s !

JAf5l-dT') \

l BEAVER VALLEY - UNIT 2 B 3/4 4-16b Amendment No.

(Proposed Wording) )

l 1

INSERT 2

a. With the PORVs inoperable and capable of being manually cycled, either the PORVs must be restored or the flow path isolated within i hour. 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, the associated vent path may be manually opened and closed, and the PORV 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 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 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.

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- . - - =- .- -~ _. - - --

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. . NPF REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RFYTEF VALVES (Continued)

ACTION (Continued) j f

/ period of time not to exceed the next refueling outage so ,

that maintenance can be performed on the PORV to return the l valve to an OPERABLE condition. Normally, the PORV should I 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 gg experience that has shown that minor problems can be corrected or closure accomplished in this time period.

lAliTH g g A;1 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 iny which the LCO does not apply.

[. If three PORVs are inoperable $ it is necessary to either l restore at least one valve within the completion time of 1 M stt/ tapke hour or isolate the flow path by closing and removing the jj -

power to the associated block valves. The completion time

@C/'p %,//7 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 i 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.

BEAVER VALLEY - UNIT 2 B 3/4 4-16c Amendment No.

(Proposed Wording)

.- NPF-73 REACTOR COOLANT SYSTEM e i BASES (Continued) i l

3/4.4.11 REACTOR COOLANT SYSTEM RFLTEF VALVES (Continued)

ACTION (Continued)

I I

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 .I 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 l hours. The allowed completion times are reasonable, based l 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.

l SURVETT T.ANCE REOUTREMENTS (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.

I 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, 1 Section XID 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, g 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 g g or c of this LCO. l f 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.

BEAVER VALLEY - UNIT 2 B 3/4 4-16e Amendment No.

(Proposed Wording) ,

ATTACHMENT B Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification Change No. 91 REVISED PORV ACTIONS A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would modify Specification 3.4.11 actions, a surveillance requirement and Bases to generally reflect the I guidance provided in NUREG-1431, " Improved Standard Technical Specifications" (ISTS) and is consistent with the changes the NRC approved for Unit No. 1. Minor editorial changes involving capitalization have also been included.

B. BACKGROUND The action statements were previously modified to address power-operated relief valve (PORV) downstream piping overstress concerns by allowing continued plant operation with one inoperable PORV as long as the block valve was closed with power removed. This was done because with the PORVs operable, the PORV inlet piping required a hot loop seal to meet acceptable downstream piping stress values following PORV actuation. With the PORV inoperable and the block valve closed, the heat tracing on the PORV inlet piping was required to be de-energized. With the heat tracing energized and if the PORV leaked by, the loop seal would evaporate.

PORV operation with no PORV inlet loop seal was not analyzed due to the existence of a postulated void in the PORV inlet piping. If the PORV did not leak by, but was inoperable, leaving the heat trace energized with the block valve closed would result in the piping between the valves without any pressure relief feature. ;

Power was required to be removed from the block valve to prevent inadvertent operation which could produce a cold loop seal slug flow resulting in unanalyzed pipe stress values. Surveillance Requirement 4.4.11.2 requires stroking the block valves quarterly unl as they are closed with power removed. Action "a" has been rev2ned to maintain power to the block valve, therefore, it can be stroked and does not need an exception to the stroking requirement.

C. JUSTIFICATION The PORV downstream piping stresses have been evaluated to determine if the piping could withstand the forces produced from a cold loop seal slug flow when the vent path is manually stroked using the block valve to control the pressure surge. The resultant downstream piping forces were found acceptable, therefore, the technical specification action statements have been developed to provide for this operating condition. Currently, actions "a," "b," )

and "c" require power removed from the block valves if they are )

closed because of inoperable PORVs. Since action "a" no longer '

requires removal of power, it can be stroked and does not need to be referenced in Surveillance Requirement 4.4.11.2. The editorial changes that have been incorporated do not affect the intent of the

i i

ATTACHMENT B, continu:d

. Proposed Technical Specification Change No. 91 Page 2 l

I applicable requirements and are provided to ensure consistency with current format and content.

D. SAFETY ANALYSIS 1

The current action "a" was written to require removal of power from I the block valve to prevent opening which could otherwise allow the PORV to open and force a cold loop seal slug flow of water down the discharge pipe. Operation in this manner would result in unanalyzed stress values on the downstream piping. Therefore, the analysis was revised to take credit for the relatively slow speed at which the block valve opens and to allow the block valve to control loop seal discharge. Energizing the PORV and then manually opening the block valve results in the PORV opening, due to the upstream pressure increase on the pilot solenoid-operated PORV, and less driving force on the loop seal. The operating characteristics of the pilot solenoid-operated PORV are such that upon achieving the required differential pressure across the pilot control valve, 1 it opens allowing full reactor coolant system pressure to drive open .the PORV valve plug. This is a fast acting design which results in high loop seal velocity and increased loading on the downstream pressurizer safety and relief piping. This downstream l loading is reduced when the block valve initially opens and allows ;

a reduced pressure build up which is sufficient to open the I solenoid-operated PORV. The slow speed of the block valve opening i reduces the resultant peak pressure surge determined by the previous analysis. The lower peak pressure surge results in acceptable downstream piping stress values, therefore, action "a" can be modified to maintain power to the block valve when it is j closed but capable of manually stroking open the PORV. The reactor j coolant system pressurizer safety and relief piping has been i l

reanalyzed in accordance with the 1989 Edition of ASME III. The original analysis was performed in accordance with ASME III, 1971 Edition, Winter 1972 Addenda. A code reconciliation was conducted and it was concluded that use of the 1989 Code is an acceptable method for the reanalysis effort. j i

Proposed action "a" is similar to that in our response to Generic l Letter (GL) 90-06 and in the ISTS concerning one or more inoperable I PORVs capable of being manually cycled. However, the actions have i been modified slightly to recognize that although there are three i PORVs installed in the plant, two are required to provide the redundancy required for continued plant operation. Proposed i actions "b" and "c" apply when inoperable PORVs are not capable of ,

being manually cycled and are similar to our GL response. However, )

action "b" includes 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. With a block valve closed to isolate a PORV that is capable of being manually B-2

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,- i ATTACHMENT B, continued Proposed Technical Specification Change No. 91 Page 3 cycled, the operator is permitted to open the block valve and use l the vent path for manual control of reactor pressure. This is J consistent with accident analysis assumptions regarding operator l actions in mitigating a steam generator tube rupture accident. l Additionally, the ability to isolate a stuck open PORV to mitigate the resultant small break loss of coolant accident remains ;

consistent with the design requirements for the block valve. It is I important to maintain block valve operability for this purpose, therefore, verification of block valve operability is required in accordance with surveillance Requirement 4.4.11.2. As a result of the change to action "a," an exception to the stroking requirements is no longer required so reference to action "a" has been deleted from Surveillance Requirement 4.4.11.2.

The action statements and Surveillance Requirement 4.4.11.2 described in the Bases for Specification 3.4.11 have been revised by incorporating the changes consistent with those the NRC approved for Unit No. 1. This generally follows the ISTS discussion with some modifications to address plant specific design requirements.

These changes remain consistent with the analysis assumptions and the operation of the PORVs in accordance with the UFSAR. The requirements of Generic Letter 90-06 are substantially addressed in the ISTS which have been incorporated here except for specific design differences. The editorial changes that have been incorporated are provided to maintain the format and content and do not affect any of the requirements, the accident analyses, or the operation of the plant. 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 quoted below:

The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment to an operating license for a facility licensed under paragraph 50.21(b) or paragraph 50.22 or for a testing facility involves no significant hazards consideration, if operation of the !

facility in accordance with the proposed amendment would not.

l (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or ;

1 (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.

B-3

1 l

ATTACHMENT B, continu:d l

- Proposed Technical Specification Change No. 91 !

Page 4 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? i l

Implementation of these changes will increase the availability of the power-operated relief valves (PORVs) and their associated block valves. The increased availability is obtained through maintaining power to the block valves which are closed to control PORV seat leakage. Maintaining power to the block valve provides the flexibility of reopening the valves to control reactor coolant system pressure. The proposed change modifies Specification 3.4.11 actions, a surveillance requirement, and Bases to generally reflect the requirements of Generic Letter (GL) 90-06, and the guidance provided in NUREG-1431, " Improved Standard Technical Specifications" (ISTS) and is consistent with the changes the NRC approved for Unit No. 1. A revised stress analysis has been completed that takes credit for the speed at which the block valve opens when manually reducing reactor coolant system pressure. The block valve relatively slow opening speed reduces the peak pressure surge and results in acceptable downstream piping stress values. The PORV downstream piping has been evaluated assuming manual vent path operation with cold loop seal slug flow and it has been determined that the piping supports can accept these design transient loads. The proposed change to the action statement to close the block valve to isolate a PORV and maintain power to the block valve )

does not significantly increase the probability of a small break loss of coolant accident. No PORV function has been deleted and the PORV and block valve continue to be capable of being manually closed at any time. As a result of the change I to action "a," an exception to the stroking requirements is no )

longer required, therefore, reference to action "a" in '

Surveillance Requirement 4.4.11.2 has been deleted. Closing the block valve for a PORV that is not capable of being manually cycled and removing power to the block valve assures )

that the valve will not be inadvertently opened when the '

condition of the PORV is uncertain.

These changes remain consistent with the analysis assumptions regarding the operation of the PORVs and block valves and provides increased assurance of their availability in mitigating the consequences of a steam generator tube rupture (SGTR) accident. The requirements of GL 90-06 are substantially addressed in the ISTS which have been incorporated here except for specific design differences.

Minor editorial changes involving capitalization have been ,

incorporated to maintain the format and content and do not i affect any of the requirements, the accident analyses, or the B-4

ATTACHMENT B, continu:d

. Proposed Technical Specification Change No. 91 Page 5 operation of the plant. Therefore, 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 to the action statements for the PORVs and the associated block valves will improve the availability of these valves for normal operation and for mitigation of a SGTR accident. The proposed changes do not involve any physical changes to the PORVs or their setpoints. These changes do not delete any design basis accident function previously provided by the PORV vent path nor has the probability of inadvertent opening been increased. Accordingly, no new limiting single failure has 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 provide the capability to manually stroke the vent path using the block valve to control the pressure surge as a PORV opens. The resultant downstream piping forces were found acceptable, therefore, power can be maintained to the block valve when the block valve has been closed to isolate a PORV because of excessive seat leakage. This will allow operation of the PORVs in a manner similar to the guidance provided in GL 90-06 to improve PORV availability. These changes will improve the operator use of an isolated PORV since it is now analyzed to be manually cycled with the block valve closed and power maintained so the operator can use the PORV if required to mitigate the effects of a SGTR accident. This is consistent with the intent of the ISTS and does not affect the UFSAR, therefore, operation of the plant in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

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

B-5

ATTACHMENT C Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification Change No. 91 Applicable Typed Pages i

W W

ATTACHMENT 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.

Remove Insert 3/4 4-39 3/4 4-39 3/4 4-39a 3/4 4-39a B 3/4 4-16b B 3/4 4-16b B 3/4 4-16c B 3/4 4-16c B 3/4 4-16d B 3/4 4-16d B 3/4 4-16e B 3/4 4-16e B 3/4 4-16f B 3/4 4-16f (Proposed Wording)

HPF-73 REACTOR COOLANT SYSTEM 3/4.4.11 RELIEF VALVES LIMITING CONDITION FOR OPERATION 3.4.11 Each Power-Operated Relief Valve (PORV) and associated l 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 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 i hour 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 BEAVER VALLEY - UNIT 2 3/4 4-39 Amendment No.

(Proposed Wording)

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s NPF-73 REACTOR COOLANT SYSTEM i I

LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)'

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. l

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 statue within j 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 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-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 raquired ACTIONS b or c.

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l BEAVER VALLEY - UNIT 2 3/4 4-39a Amendment No.

(Proposed-Wording)

- NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES (Continued)

APPLICABILITY (Continued)

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 l block valves, since removal of power would render the j block valve inoperable. Although a PORV may be I designated inoperable, the associated vent path may be i manually opened and closed, and the PORV therefore, able l to perform its function. PORV inoperability may be due I 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 i maintained to the valve. Automatic control problems and i related instrumentation problems would not render the j PORVs inoperable. Accident analyses assume manual operation of the PORVs and does not take credit for automatic actuation. This condition is only BEAVER VALLEY - UNIT 2 B 3/4 4-16b Amendment No.

(Proposed Wording)

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. l NPF-73

-REACTOR COOLANT SYSTEM 1

BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES (Continuedi 1

ACTION (Continued) 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 j eliminate the seat leakage condition. Normally, the l PORVs should be available for automatic mitigation of j overpressure events and should be returned to OPERABLE ,

status prior to entering startup (MODE 2). I Quick access to the PORV for pressure control can be made when power remains on the closed block valve. The i 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 i 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 l the operator time to correct the situation. If one PORV l is restored, then the plant will be in a less limiting i BEAVER VALLEY - UNIT 2 B 3/4 4-16c Amendment No.

(Proposed Wording) l

. NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 REACTOR COOIANT SYSTEM RELIEF VALVES (Continued)

ACTION (Continued) 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 necetsary to either restore the block valve to OPERABLE stas s 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 hour 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 BEAVER VALLEY - UNIT 2 B 3/4 4-16d Amendment No.

(Proposed Wording)

NPF-73 '

REACTOR COOLANT SYSTEM BASES (Continued) i 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES (Continued)

ACTION (Continued) 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 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 l 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 i required. See LCO 3.4.9.3.

SURVEILLANCE REOUIREMENTS (SR) 1 SR 4.4.11.1 This surveillance requires a complete cycle of each PORV. I 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. !

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BEAVER VALLEY - UNIT 2 B 3/4 4-16e Amendment No.

(Proposed Wording) l l

. - NPF-73 REACTOR COOLANT SYSTEM BASES (Continued) 3/4.4.11 REACTOR COOLANT SYSTEM RELIEF VALVES (Continued)

SURVEILLANCE REOUIREMENTS (SR) (Continued) l 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 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 b or c of this LCO.

l 3/4.4.12 REACTOR COOLANT SYSTEM HEAD VENTS Reactor Coolant System Vents are provided to exhaust noncondensible gases and/or steam from the primary system that could inhibit natural circulation core cooling. The OPERABILITY of at least one reactor coolant system vent path from the reactor vessel head or the pressurizer steam space via the PORV's ensures the capability exists to perform this function.

The valve redundancy of the Reactor Coolant System Head vent i I

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 Requirements," November 1980.

BEAVER VALLEY - UNIT 2 B 3/4 4-16f Amendment No.

(Proposed Wording)

(ACCELERATED RIDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9507310172 DOC.DATE: 95/07/24 NOTARIZED: NO DOCKET #

FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 P AUTH.NAME AUTHOR AFFILIATION WEBER,G.A. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele R 1 BLIND,A.A. Indiana Michigan Power Co. (formerly Indiana & Michigan Ele RECIP.NAME RECIPIENT AFFILIATION I

SUBJECT:

LER 95-002-00:on 950620,21,22 & 23,nine Unit 1 MSSVs lift setpoints above TS allowed values occurred. Caused by high 0 as-found lift setpoints attributed to mild galling between disc & nozzle.Eight of nine MSSVs lifted.W/950724 ltr. R DISTRIBUTION CODE: IE22T COPIES RECEIVED:LTR _] ENCL SIZE:

TITLE: 50.73/50.9 Licensee Event Report (LER), Inciden Rpt, etc. I NOTES:

RECIPIENT COPIES RECIPIENT COPIES i ID CODE /NAME LTTR ENCL ID CODE /NAME LTTR ENCL yl PD3-1 PD 1 1 HICKMAN,J 1 1 INTERNAL: AEOD/SPD/RAB 2 2 AEOD/SPD/RRAB 1 1 I FILE CENTER 1 1 NRR/DE/ECGB 1 1 1)

NRR/DE/EELB 1 1 NRR/DE/EMEB 1 1 NP.R/ DISP /PIPB 1 1 NRR/DOPS/OECB 1 1 NRR/DRCH/HHFB 1 1 NRR/DRCH/HICB 1 1 NRR/DRCH/HOLB 1 1 NRR/DSSA/SPLB 1 1 D NRR/DSSA/SPSB/B 1 1 NRR/DSSA/SRXB 1 1 RES/DSIR/EIB 1 1 RGN3 FILE 01 1 1 o

f EXTERNAL: L ST LOBBY WARD 1 1 LITCO BRYCE,J H 2 2 NOAC MURPHY,G.A 1 1 NOAC POORE,W. 1 1 C

NRC PDR 1 1 NUDOCS FULL TXT 1 1 U

M E

N T

NOTE TO ALL " RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SDB (415-2093) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

FULL TEXT CONVERSION REQUIRED TOTAL NUMBER OF COPIES REQUIRED: LTTR 26 ENCL 26 i

ML20086R934

Text

SUBJECT:

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