ML20091F407

Requests NRC Approval of Temporary Waiver of Compliance in Meeting Unit Restart Phase Following Plant Shutdown of Approx thirty-seven Days

ML20091F407
Person / Time
Site:	Beaver Valley
Issue date:	11/27/1991
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20091F402	List: ML20091F407
References
NUDOCS 9112060145
Download: ML20091F407 (5)

Text

412 643 4671 11/27/91-10 27 0412 643 4671 DLC @001 t .

gve ejev Power station gge ng>A en-0004 November 27, 1991 JOHN D SICBER V!ce President - Nuoleer Group U. S. Nuclear Regulatory Commission Attn Document Control Desk Washington, DC 20555

Subject:

Bcaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Request for Temporary Waiver of Compliance The purpose of this letter is to request NRC approval of a temporary waiver of complianco in meeting the Beaver Valley Un!b No. 1 technical specifications. Unit No. 1 is currently in the restart phase following a plant shutdown of approximately 37 days.

The Limiting Condition for operation (LCO) for the auxiliary feedwater system requires at least three steam generator auxiliary feedwater pumps (two motor-drivan, one steam turbine-drivon) to be operable in modes 1, 2, and 3. Surveillance requirement 4.7.1.2.a.2 directs the plant to demonstrate operability of the steam turbine-driven auxiliary feedwater pump when the secondary steam pressure is greater than 600 psig. Therefore, entry into mode 3 la required to achieve test conditions. However, the action statement places a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> restriction on the time allowed to declare an inoperable pump operable, otherwise, the plant must roturn to mode 4.

During testing of the turbine-driven auxiliary feedwater pump the pump demonstrated unstable performance necessitating repairs and rotonting. At the time of failuro thoro was approximately 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> remaining in the technical specification action statomont for declaring this pump operable. It has been determined that repairs and ratesting may take longer than the LCO action time. However, the work is expected to be completed within the following 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

This roquent is for a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> extension of an action atatement time limit to allow maintenance and testing to be completed to declaro the pump operable. Prompt action is necdod to avoid a short duration modo change back to modo 4, which would place an unnecessary thermal cycle on the reactor plant. Since the plant in in a restart nequenco following an outage, it is anticipat ed that entry into mode l 1 would occur within the next 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

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412 643 4671 11/27/91 17:22 0412 643 4671 liLC gg,i Request for Temporary Waiver of Compliance Page 2 This requent in characterized an a regional waiver of compliance since the relief is temporary and non-rocurring such that a permanent license amendment is not appropriate. Plant nafoty is promoted by avoiding an unnecessary reactor plant thermal cycle and ruactor start-up is supported by remaining in mode 3. Approval of this request precludes changing to mode 4 and delaying the prenant restart schedule.

Our evaluation of this request concludos there is no reduction of safety margin or changou to oIrsite dono annumptions since two motor driven auxiliary feedwater pumpn are operable and capablo of removing decay heat.

Add _cional details supporting thin request are located in the enclosure which addresses the curront understanding of the level of detail required with respect to requesting a temporary waiver of compliancu. This requent has been reviewed by our onsite safety committna.

If you have any questions regarding this submittal, pleano call Steve Sovick on (412) 393-5211.

Sincerely, w( C $ w ,fs-J. D. Sieber cc Mr. J. Beall, Sr. Ronident Inspector Mr. T. T. Martin, NRC Region 1 Adminintrator Mr. A. L DnAgazio, Project Manager Mr. M. L. Bowling (VEPCO)

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11/27/01 10:28 17412 043 4071 C 0003 ATTACHMENT Evaluation Supporting a Temporary Waivor of compliance (Ret Inoperabic Steam Turbino-Driven Aux)11ary Fondwater Pump)

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1. Discuss the requiromonto for which a waivor is requentod:

This waiver addrences Technical Specification Limiting Conditir of Operation (LCO) 3.7.1.2.b " Auxiliary Feedwater Syntum." Th LCO requires the steam turbino-driven auxiliary foodwater pump r be operable in modes 1, 2, and 3.

Surveill.ance requiremont 4.7.1.2.a.2 directs the plant to domonstrate operability of the stoam turbino-driven auxiliary feidwater pump when the secondary stean pressure in greater than Goo pali. Therefore, entry into mode 3 is required to achieve test conditions. The roanon for this in that the plant has to haat up cufficiently to provide a steam nourco to operata the turbine-driven pump. Whilu in this configuration, action statement Ha" of LCO 1.7.1.2 is in offect, which requirco '

rostoring the inoperm pump to operable statun within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or bo in hot shutdnwn thin the next 12 hourn. Therefore, plant conditions and toncing muut be ccmploted within this tino poriod, otherwiso, it iu required that the plant return to modo 4.

We are unable to natisfactorily completo the required tanting to declare the pump operablo within the time constrainto specified in the LCO action statomont. Maintenance activities are in progreus and tusting in expected to be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> a*ter the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action time expiron. We, therefore, roquest a temporary waivor of compliances from meeting technical specification LCO action statement 3.7.1.2.a for a nhort duration of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> so the plant may remain in mode 3 to complete the maintenance and tonting on the steam turbine-drivet. auxiliary feedwater pump.

2. Discuss the circumstances surrounding the situation including the need for prompt action, and why the nituation could not have been avoided:

beaver Valley Unit No. 1 is performing the actions noconnary to support contart following a 37 day outage. The plant is in modo 3 and it is anticipated that entry into modo 1 will occur within the next 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

The plant entered mode 3 at 2230 hours0.0258 days <br />0.619 hours <br />0.00369 weeks <br />8.48515e-4 months <br /> on November 25, 1991, and had to demonstrata operability of tho 9tcam turbino-driven auxiliary feedwater pump as stated in item ' mbove. Tonting to demonstrate oporability began at approximatury 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> on November 26, however, the pump demoastrated unstable performance and the acceptance critorie or survoillance requirement 4.7.1.2.a.2 could not be satirfied.

1

11[27/91 10:28 0412 043 4071 ItC I!J 004 s

1

- Attachment, continued Temporary Waivor of compliance Pagn 2 Maint3nanco a ti.vities were immediatnly initiated to replace the governor and nesess other potential causes of the unste.alu performance, nowever, approximately So hours romainud au thu timo required to declare this pump oporablo. It has been concludnd that the maintenance and test activition cannot be complated Within cuYYont time coh8tPhinto. Hownver, if a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> oxtension to the action statement is granted, we will be able to comploto the current maintenance and testing activitien and avoid a thermal cycIn back to mode 4.

3. Discuna compensatory actiunu (if any):

The plant will romain in mode 3 for the duration of the approved temporary waivor of compliance, wo will open the reactor trip breakers and place them on cloavance to remove the potential for plant heatup due to roactor criticality. Upon expiration of the temporary valver we will adhore to the existing tuchnlcal specifications.

4. Provido a prcliminary evaluation of the uafety significanco and potential consequences of the proposed request:

The function of the auxiliary feedwater ayatem in to provido a huat aink for the reactor coolant nyntom. This is accomplinhed by providing 350 gpm flow to the nteam generators whilo annuming a loss of offsite power and a single failure (ion one energsney diesel generator fails to statt). Both motor driven auxiliary feedwater pumps are capablo of providing 350 gpm flow dnd both are operable. Should one of theno become inoperablo, the plant would be plaand in mode 4 a r. required by LCO 3.7.1.2. The turbinn-driven auxiliary foodwater pump is designed to provide 700 gpm flow to the ntnam gonorators upon loss of offolto power or low-low ntnam gonorator level.

With the plant on a restart schedulo following this , atago, the potential radioactivity releases, due to an uncontrolled heatup of the reactor coolant system, are envoloped by the releases poatulaced in the DBA LOCA analynic in the UFSAR. Thic analysis annumos 102 percent power operation prior to the event and assumes that a coro molt occurs. Tnoroforo, thore is no increano in radiological consequences.

One notor-driven auxiliary foodwatnr pump is all that is required to sat sfy accident conditions. Current plant conditionn (1e: a 11abin equipment, heat load, nourco torm) all renuit in margin to annumed accident conditions. Maintaining the reactor trip breako.' open assures the reactor will not go critical and add reactor 4.'at or change the source term during this roquanted tamparary valver.

, 1,1/27/01 10:20 G 412 043 4071 DLc 0005 At'tachment, continued Temporary Waivor of Compliance Page 3 Thornforo, the extension of tino in mode 3 with the steam-driven auxiliary feedwater pump ihoperable vill not tapact the offnite radiological connoquencou of loss of offsite power or loss of feedwater ovents. There are no changes to the ronuits of our safety analysen and, therefore, no increase in the potential consequuncun of any postulated accident.

By avoiding a thermal cycin on the reactor plant we arn not imposing unnecessary actions on the plant and are maintaining the reactor start-up schedule, which would othorwiuo, be procluded by technical specifications. This propouwd couran of action involvon no reduction in the plant's safety ponturo.

5. Discuss juntification for the duration of the request:

Thin additional tien in needed to avoid a short duration modo change back to modo 4. . It is anticipated that the maintenance on the governor, the adjustmenta nocessary to provido acceptabin test results and the satinfactory completion of the operability test will be completed within the time requested in this temporary waivor of complianco (barring unfornnoon additional proalems). Approval of thin short duration extension of tha action statomont will allow un to avoid an unnoccusary thermal cycle on the reactor plant.

6. Provido a basis for the conclusion that the requent does to involve a sinnificant hazards considoration:

The change in the action statomont time limit will not increano the probability of an accidwnt ptuviously evaluatod. The auxiliary feedwato! system will romain capable of romoving decay heat from the reactor corn. There is no nafoty analyses inpact or chango in offsito dono consequences an a result of romaining in modo 3 for an additional 48 hourn. On this bania it is concluded that this request doon not involve a significant hazarda consideration.

7. Provide a banis for the conclusion that the request doon not involva irreversible environmental conseguonces:

The offsite doso analyser. and accident analysos are not affected. There is no planned reloano to tho environment as a result of this request. Thereforo, based on the continued ability of the auxiliary fondwater system to remove decay heat, and no pontulated reloano to the environrent, this chango does not involvo irreversinio environmental consequences.

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