ML20101M354

Proposed Tech Specs Incorporating Addl Administrative Controls to Provide Protection from Pressure Transients at Low Temp & Changes to Address NRC 830404 Comments

ML20101M354
Person / Time
Site:	Beaver Valley
Issue date:	12/21/1984
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20101M342	List: ML20101M339 ML20101M351 ML20101M354
References
NUDOCS 8501030057
Download: ML20101M354 (18)

Text

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ATTACHMENT A Revise Appendix A as follows:

Remove Pages Insert Pacy 3/4 1-11 3/4 1-11 3/4 1-12 3/4.1-12 B3/4 1-2 B3/4 1-2 3/4 4-2c 3/4 4-2c 3/4 4-4a B3/4 4-la B3/4 4-la 3/4 4-27a 3/4 4-27b B3/4 4-10 B3/4 4-10 3/4 5-2 3/4 5-2 3/4 5-6 3/4 5-6 3/4 5-7a B3/4 5-1 B3/4 5-1 g$1%o0k0 $

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. REACTIVITY CONTROL SYSTEMS CHARGING PUMP - SHUTDOWN-LIMITING CONDITION FOR OPERATION 3.1.2.3 One charging pump in _the boron _ injection Eflow ' path required by Specification (3.1.2.1) shall be OPERABLE and capable' of being powered from an OPERABLE emergency bus.

APPLICABILITY: MODES 5 and 6 ACTION:

With no charging pump OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes until one charging pump ' is restored to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.1.2.3.1 The above required charging pump shall be demonstrated OPERABLE at least once per 31 days by:

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a. Starting (unless already operating) the pump from the control room, '

b. Verifying, that on recirculation fl ow, the pump develops a discharge pressure of > 2402 psig and,

c. Verifying pump operation for at least 15 minutes.

, 4.1.2.3.2 All charging pumps, except the above required OPERABLE pump, shall l be demonstrated inoperable at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> be verifying that the control switches are placed in the PULL-TO-LOCK position and tagged.

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BEAVER VALLEY - UNIT 1 3/4 1-11 PROPOSED WORDING i

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REACTIVITY CONTROL SYSTEMS CHARGING PUMPS OPERATING LIMITING CONDITION FOR OPERATION 3.1.2.4 At least two charging pumps shall be OPERABLE APPLICABILITY: MODES 1, 2, 3, and 4# l ACTION:

With only one charging pump OPERABLE, restore at least two charging pumps to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least H0T STANDBY and borated to a SHUTDOWN MARGIN equivalent to at least 1% ak/k at 200 F within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />; restore at least two charging pumps to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4.1.2.4.1 At least two charging pumps shall be demonstrated OPERABLE at least once per 31 days by:

a. starting (unless already operating) each pump from the control room,

b. verifying, that on recirculation flow, each pump develops a discharge pressure of > 2402 psig, and

c. verifying pump operation for at least 15 minutes.

4.1.2.4.2 All charging pumps, except the above required OPERABLE pump, shall be demonstrated inoperable at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> whenever the temperature of one or more of the in-service RCS cold legs is < 275 F by

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verifying that the control switches are placed in the PULL-TO-LOCI < position and tagged.

1. A maximum of one centrifugal charging pump shall be OPERABLE whenever '

the temperature of one or more of the non isolated RCS cold legs is

< 275 F.

BEAVER VALLEY - UNIT 1 3/4 1-12 PROPOSED WORDING

4 3/4.1 REACTIVITY CONTROL SYSTEMS BASES 3/4.1.1.4 MODERATORTEMPERATUREC0 EFFICIENT (MTC)(Continued) fuel cycle. The surveillance requirement for measurement of the MTC at the beginning and near the end of each fuel cycle is adequate to confirm the MTC value since this coefficient changes slowly due principally to the reduction in RCS boron concentration associated with fuel burnup.

3/4.1.1.5 MINIMUM TEMPERATURE FOR CRITICALITY This specification ensures that the reactor will not be made critical with the Reactor Coolant System average temperature less than 541 F. This limitation is required to ensure 1) the moderator temperature coefficient is within its analyzed temperature range, 2) the pressurizer is capable of being in an OPERABLE status with a steam bubble, 3) the reactor pressure vessel is above its minimum NDTT temperature and 4) the protective instrumentation is within its normal operating range.

3/4.1.2 B0 RATION SYSTEMS The boron injection system ensures that nc iative reactivity control is available during each made of facility operation. The components required to perform this function include 1) borated water sources, 2) charging pumps, 3) separate flow paths, 4) boric acid transfer pumps, 5) associated heat tracing systems, and 6) an emergency power supply frcm OPERABLE diesel generators.

With the RCS average temperature above 200 F, a minimum of two separate and redundant boron injection systems are provided to ensure single functional capability in the event an assumed failure renders one of the systems inoperable. Allowable outofservice periods ensure that minor component repair or corrective action may be completed without undue risk to overall facility safety from injection system failures during the repair period.

The required volume of water in the refueling water storage tank for reactivity considerations while operating is 424,000 gallons. The associated technical specification limit on the refueling water storage tank has been established at 441,100 gallons to account for reactivity considerations and the NPSH requirements of the ECCS system.

The limitations for a maximum of one centrifugal charging pump to be OPERABLE and the Surveillance Requirement to verify all charging pumps except the required OPERABLE pump to be inoperable below 275 F provides assurance that a mass addition pressure transient can be relieved by the operation of a single PORV.

BEAVER VALLEY - UNIT 1 B 3/4 1-2 PROPOSED WORDING

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l REACTOR COOLANT SYSTEM SHUTDOWN .

LIMITING CONDITION FOR OPERATION i

3.4.1.3 a. At least two of the coolant loops listed below shall- be.

OPERABLE:

1. Reactor Coolant Loop (A) and its associated steam ,

generator and reactor coolant pump, l

2. Reactor Coolant Loop (B) and its associated steam generator and reactor coolant pump, l

3. Reactor Coolant Loop (C) and its associated steam j generator and reactor coolant pump. l

4. Residual Heat Removal Pump (A) and a heat exchanger,**

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5. Residual Heat Removal Pump (B) and a second heat exchanger.**

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b. At least one of the above coolant loops shall-be in operation.***

APPLICABILITY: MODES 4 and 5 l ACTION:

a. With less than the above required loops OPERABLE, immediately

initiate corrective action to return the required loops to 1 OPERABLE status as soon as possible; be in COLD SHUTDOWN I within 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.

b. With no coolant loop in operation, suspend all operation 1 involving a reduction in boron concentration of the Reactor Coolant system and immediately initiate corrective action to return the required coolant loop to operation. Refer to Specification 3.4.1.6 for additional limitations.

• • The normal or emergency power source may be inoperable in MODE 5.

• • • All reactor coolant pumps and Residual Heat Removal pumps may be

,. deenergized for up to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> provided: 1) no operations are permitted i

that would cause dilution of the reactor coolant system boron

concentration and 2) core outlet temperature is maintained at least 10 F below saturation temperature, I

BEAVER VALLEY - UNIT 1 3/4 4-2c l PROPOSED WORDING i

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REACTOR COOLANT SYSTEM REACTOR COOLANT PUMP STARTUP-LIMITING CONDITION FOR OPERATION 3.4.1.46 -If both OPPS PORV's are not OPERABLE, 'tn idle reactor coolant pump in a non isolated loop shall not be started, unless:

1. .The actual pressurizer water level is less than 60 percent (840 ft3),:or

2. The secondary water temperature

• of each steam generator-is less than 25 F above each of the in-service RCS cold leg temperatures.

APPLICABILITY: When the temperature of one or more of the non-isolated loop cold legs is < 275 F.

ACTION:

With the pressurizer water level greater than 60 percent _or the temperature of the steam generator in the loop associated with the reactor coolant ~ pump.

being started greater than 25 above the cold leg temperature of the other non isolated loops, suspend the startup. of the reactor coolant pump.

SURVEILLANCE REQUIREMENTS:

4.4.1.6.1 The pressurizer water volume or the secondary water temperature of the non isolated steam generators shall be determined within ten minutes

prior to starting a reactor coolant pump.

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• The secondary water temperature is to be verified by direct measurement of the fluid temperature, or contact temperature readings on the steam generator secondary, or blowdown piping after purging of stagnant water within the piping.

BEAVER VALLEY UNIT 1 3/4 4-4a PROPOSED WORDING

3/4.4 REACTOR COOLANT SYSTEM -

BASES 3/4'. 4.1 REACTOR COOLANT LOOPS, (continued) of Appendix G by either (1) restricting the water level in the pressurizer l and thereby providing a volume for the primary coolant to expand into or (2) by restricting starting of the RCPs to when the secondary water temperature of each steam generator is less -than .25 F above each of the RCS cold leg l temperatures.

The requirement to maintain the boron concentration of an isolated loop greater than or equal to the boron concentration of the operating loops

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ensures that no reactivity addition to the core could occur during startup of an isolated loop. Verification of the boron concentration in an idle loop immediately prior to opening the stop valves provides a reassurance of the adequacy of the boron concentration in the isolated loop. Operating the isolated loop on recirculating flow for at least 90 minutes prior to opening its stop valves ensures adequate mixing of the coolant in this loop and prevents any reactivity effects due to boron concentration stratifications.

Startup of an idle loop will inject cool water from the loop into the core. The reactivity transient resulting from this cool water injection is minimized by delaying isolated loop startup until its temperature is within 20 F of the operating loops. Making the reactor subcritical prior to loop startup prevents any power spike which could result from this cool water induced reactivity transient.

3/4.4.2 and 3/4.4.3 SAFETY VALVES The pressurizer code safety valves operate to prevent the RCS from being pressurized above is Safety Limit of 2735 psig. Each safety valve is designed to relieve 345,000 lbs. per hour of saturated steam at the valve set point. The relief capacity of a single safety valve is adequate to i

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BEAVER VALLEY - UNIT 1 B 3/4 4-la PROPOSED WORDING

REACTOR COOLANT SYSTEM OVERPRESSURE PROTECTION SYSTEMS LIMITING CONDITION FOR OPERATION 3.4.9.3 At least one of the following overpressure protection systems shall '

be OPERABLE:

a. Two power operated relief valves (PORVs) with a nominal trip setpoint of 5 350 psig, or

b. A reactor coolant system vent of > 3.14 square inches.

APPLICABILITY: When the temperature of one or more of the non isolated RCS cold legs is 1 275 F.

ACTION:

a. With one PORV inoperable, either ~ restore the inoperable PORV to OPERABLE status within 7 days or depressurize and vent the RCS through a 3.14 square inch vent (s) within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; maintain the RCS in a vented condition until both PORVs have been restored to OPERABLE status. Refer to Technical Specification 3.4.1.6 for further limitations,

b. With both PORV's inoperable, depressurize and vent the RCS through a 3.14 square inch vent (s) within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />; maintain the RCS in a vented condition until both PORVs have been restored to OPERABLE status,

c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENT i

4.4.9.3.1 Each PORV shall be demonstrated OPERABLE BY:

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BEAVER VALLEY UNIT 1 3/4 4-27a PROPOSED WORDING

REACTOR COOLANT SYSTEM SURVEILLANCE REQUIREMENTS (Continued)

a. 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 OPERABLE and at least once per 31 days thereafter when the PORV is required OPERABLE.

b. Performance of a CHANNEL CALIBRATION on the PORV actuation channel at least once per 18 months.

c. Verifying the PORV isolation valve is open at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when the PORY is being used for overpressure protection.

d. Stroking the operable PORV(s) each time the plant enters Mode 5, unless tested within the preceding three months.

4.4.9.3.2 The > 3.14 square inch RCS vent (s) shall be verified to be open at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

• when the vent (s) is being used for overpressure protection.

• 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 i open at least once per 7 days.

BEAVER VALLEY UNIT 1 3/4 4-27b PROPOSED WORDING 1

REACTOR COOLANT SYSTEM BASES 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 the calE0IatedaRT NDT f r the equivalent capsule radiation exposure.

The pressure-temperature limit lines shown on Figure 3.42 for reactor criticality and for inservice leak and hydrostatic testing have been provided to assure compliance with the minin,um 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 Table 4.43 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 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.

The OPERABILITY 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 wh>r one or more of the RCS cold legs are < 275 F. Either PORV has adequate reiieving capability to protect the RCS ~from overpressurization when the transient is limited to either (1) the start of an idle RCP with the sec-ondary water temperature of the steam generator < 25 F above the RCS cold leg

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temperature or (2) the start of a charging pu p and its injection into a water solid RCS.

3/4.4.10 STRUCTURAL INTEGRITY i 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 Conmission pursuant to 10 CFR Part 50.55a (g)(6)(1).

3/4.4.11 RELIEF VALVES The relief valves have remotely operated block valves to provide a positive shutoff capability should a relief valve become inoperable. The electrical power for both the relief valves and the block valves is capable of being supplied from an emergency power source to ensure the ability to seal this possible RCS leakage path.

BEAVER VALLEY - UNIT 1 B 3/4 4-10 PROPOSED WORDING l

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EMERGENCY CORE COOLING SYSTEMS l

I SURVEILLANCE REQUIREMENTS (Continued) 1

b. At least once per 31 days and within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each solution i volume increase of greater than or equal to 1% 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 be 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.

d. Verifying at least once per 18 months that each accumulator isolation valve opens automatically under each of the following conditions:

1. When the RCS pressure exceeds 2000 psig.

2. Upon receipt of a Safety Injection test signal 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.

4.5.1.3 During normal plant cooldown and depressurization, each accumulator discharge isolation valve [MOV-1SI-865A, B and C] shall be verified to be closed and de-energ' zed when RCS pressure is reduced to 1,000 100 psig.

BEAVER VALLEY UNIT 1 3/4 5-2 PROPOSED WORDING

r EMERGENCY CORE COOLING SYSTEMS ECCS SUBSYSTEMS T <350 F 3yg LIMITING CONDITION FOR OPER/. ION 3.5.3 As a minimun, one ECCC subsystem comprised of the following shall be OPERABLE:

a. One OPERABLE centrifugal charging pump,# l

b. One OPERABLE Low Head Safety Injection Pump, and

c. An OPERABLE flow path capable of taking suction from the refueling water storage tank upon being manually realigned and transferring suction to the containment sump during the recirculation phase of operation.

APPLICABILITY: MODE 4.

ACTION:

a. With no ECCS subsystem OPERABLE because of the inoperability of either the centrifugal charging pump or the flow path from the refueling water storage tank, restore at least one ECCS subsystem to OPERABLE status within 1 hour or be in COLD SHUTDOWN within the next 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.

b. In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.

SURVEILLANCE REQUIREMENTS 4.5.3.1 The ECCS subsystem shall be demonstrated OPERABLE per the appli-cable Surveillance Requirements of 4.5.2.

4.5.3.2 All charging pumps except the above required OPERABLE pumps, shall be demonstrated inoperable at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> whenever the temperature of one or more of the non isolated RCS cold legs is < 275 F by verifying that the control switches are placed in the PULL-T0-LOCR position and tagged.

1. A maximum of one centrifugal charging pump shall be OPERABLE whenever the temperature of one or more of the non isolated RCS cold legs is < 275 F.

BEAVER VALLEY UNIT 1 3/4 5-6 PROPOSED WORDING

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EMERGENCY CORE COOLING SYSTEMS 3/4.5.4 BORON INJECTION SYSTEM BORON INJECTION TANK <350 F LIMITING CONDITION FOR OPERATION 3.5.4.1.2 The boron injection tank flow path shall be isolated and power removed from the inlet or outlet valves.

APPLICABILITY: When the temperature of one or more of the non isolated RCS cold legs is < 275 F.

ACTION:

With the boron injection tank not isolated, isolate the tank flow path and remove power from the inlet or outlet valves.

SURVEILLANCE REQUIREMENTS 4.5.4.1.2 The boron injection tank flow path shall be verified isolated by verifying at least once per 7 days that the Boron Injection Tank inlet or outlet valves are closed and de-energized except for purposes of flow testing or valve stroke testing.

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BEAVER VALLEY - UNIT 1 3/4 5-7a PROPOSED WORDING l

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c 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

BASES 3/4.5.1 ACCUMULATORS The OPERABILITY of each of the RCS accumulators ensures that a suffi-cient volume of borated water will be immediately forced into the reactor core through each of the cold legs in the event the RCS pressure falls below .

the pressure of the accumulators. This initial surge of water into the core l provides the initial cooling mechanism during large RCS pipe ruptures. l The limits on accumulator volume, baron concentration and pressure j ensure that the assumptions used for accumulator injection in the '

accident analysis are met.

The limit of one hour for operation with an inoperable accumulator  !

minimizes the time exposure of the plant to a LOCA event occurring concurrent with failure of an additional accumulator which may result in unacceptable peak cladding temperatures.

The RCS accumulators are isolated when RCS pressure is reduced to 1000 100 psig to prevent borated water from being injected into the RCS during normal plant cooldown and depressurization conditions and also to prevent inadvertent overpressurization of the RCS at reduced RCS temperature.

3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS The OPERABILITY of two separate and independent ECCS subsystems ensures that sufficient emergency core cooling capability will be available in the  ;

event of a LOCA assuming the loss of one subsystem through any single failure '

consideration. Either subsystem operating in conjunction with the ,

accumulators is capable of supplying sufficient core cooling to limit the '

peak cladding temperatures within acceptable limits for all postulated break sizes ranging from the double ended break of the largest RCS cold leg pipe downward. In addition, each ECCS subsystem provides long term core cooling capability in the recirculation mode during the accident recovery period.

The Surveillance Requirements provided to ensure OPERABILITY of each component ensures that at a minimum, the assumptions used in the accident analyses are met and that subsystem OPERABILITY is maintained.

The limitation for a maximum of one charging pump to be OPERABLE and the Surveillance Requirement to verify all charging pumps except the required

OPERABLE pump to be inoperable below 275 F provides assurance that a mass addition pressure transient can be relieved by the operation of a single l 1

PORV.

( 3/4.5.4 BORON INJECTION SYSTEM The OPERABILITY of the boron injection system as part of the ECCS ensures that sufficient negative reactivity is injected into the core to

limit any positive increase in reactivity caused by RCS system cooldown. RCS cooldown can be caused by inadvertent depressurization, a loss-of-coolant I accident or a steam line rupture. l I

The boron injection tank is required to be isolated when RCS temperature l is less than 350 F to prevent a potential overpressurization due to an inadvertant safety injection signal.

BEAVER VALLEY - UNIT 1 B3/4 5-1

! PROPOSED WORDING ,

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ATTACHMENT B Safety Evaluation )

Proposed Change Request No. 34, Revision 1 amends the ' Beaver Valley l Power Station, Unit No.1 Technical Specifications, Appendix A to address the comments identified by the NRC Overpressure Protection System safety eval-uation provided by letter dated April 4,1983.

Description and Purpose of Change The proposed changes have been incorporated to reduce the probability of an overpressurization event occurring and to comply with General Design Criteria 15 and 31 of 10 CFR 50 Appendix A. l

1. page 3/4 1-11, Section 3.1.2.3, Charging Pump - Shutdown, has been revised to specifically identify the one charging pump in the boron injection flowpath required by Specification 3.1.2.1. Section 4.1.2.3.2 has been added to require verification that only one charging pump is operable.

2. page 3/4 1-12, Section 3.1.2.4, Charging Pumps - Operating, has been revised by adding a # note applicable to Mode 4 which places a limit of one operable charging pump whenever the temperature of the RCS is less than 275*F. The Action statement has been revised to specify the minimum SHUTDOWN MARGIN requirements equivalent to 1% ak/k at 200*F.

Section 4.1.2.4.2 has been added, applicable when the RCS temperature is

< 275*F, to require demonstrating once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that all except the l

required operable charging pump are inoperable.

3. page B3/4 1-2, Bases Section 3/4.1.2, provides the basis for allowing I only one charging pump to be OPEPABLE below 275 F.

4. page 3/4 4-2c, Section 3.4.1.3.a has been revised by deleting the

• note since this note has been incorporated into a new specification 3.4.1.6.

5. page B 3/4 4-la, Bases Section 3/4.4.1 has been revised to specify the requirements of Section 3.4.1.6.

6. page 3/4 4-4a, Section 3.4.1.6 has been added to ensure the minimum conditions are met prior to starting a reactor coolant pump.

7. page 3/4 4-27a, Section 3.4.9.3 has been added to require an overpres-sure protection system consisting of two power-operated relief valves or an RCS vent of 3.14 square inches and also specifies when the overpres-sure protection system is to be enabled for low temperature operation.

Section 4.4.9.3.1 has been added to specify PORV surveillance require-ments when used for the low temperature overpressure protection system.

System 4.4.9.3.2 has been added to specify surveillance requirements for the RCS vent when it is being used for the low temperature overpressure protection system.

Safety Evaluation 1A-34 Page 2

7. page B 3/4 4-10, Bases Section 3/4.4.9 has been revised to incorporate the basis for the overpressure protection system.

8. page 3/4 5-2, Section 4.5.1.3 has been added to ensure that the accumu-lators have been isolated during plant cooldown following RCS pressure reduction to less 1000 1 100 psig.

9. page 3/4 5-6, Section 3.5.3 has been revised by' adding a # note applica-ble to the charging pump to limit the number of operable pumps to one when the RCS temperature is less than 275 F. Section 4.5.3.2 has been added to ensure verification of the above specificntion requirements.

10. 'page 3/4 5-7a, Section 3.5.4.1.2 has been added to require isolation of the Boron Injection Tank when the RCS temperature is less than 275 F.

Section 4.5.4.1.2 has been added to require verification of the above specification requirements.

11. page B 3/4 5-1, Bases Section 3/4.5.1 has been revised to provide the basis for isolating the accumulators during normal plant cooldown and depressurization conditions. Bases Section 3/4.5.2 and 3/4.5.3 have been revised to provide a basis for the change to Section 3.5.3 which requires the operability of one and only one charging pump when the RCS temperature is less than 275*F. Bases Section 3/4.5.4 has been revised to provide a basis for isolating the Baron Injection Tank required by Section 3.5.4.1.2.

Basis For Proposed No Significant Hazards Consideration Determination The proposed changes impose new requiremants on portions of systems previously not governed by the Technical Specifications. The changes reflect additional administrative controls and plant modifications presently in effect to provide additional protection from reactor coolant system pressure transients.

The Commission has provided guidance concerning the application of these standards by providing certain examples (48 FR 14870). One of these, Example (ii), involving no significant hazards consideration is "A change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications". The proposed changes impose new requirements which match this example. Thus, based on the above example, it is proposed that the changes be characterized as involving no significant hazards consideration.

We have identified changes in addition to those provided by our letter dated May 31, 1983. The differences are described as follows:

1. page 3/41-11 has been revised by deleting reference to using the LHSI pumps in lieu of a charging pump. This will be the subject of future Licensing action.

Safety Evaluation 1A-34 Page 3

2. page 3/41-12, the present surveillance requirement 4.1.2.4.1 has been retained.

3. page 3/4 4-4a, Section 3.4.1.6.1 has been revised to reflect the Pressurizer Bubble Cold Overpressure Analysis Report which limits the pressurizer level to 60%. This is also consistent with the pressurizer level indication available to the operator. Therefore, requiring a maximum pressurizer level in lieu of a pressurizer volume will allow the operator to more easily identify with the required limit. Section 3.4.1.6.2 has been revised to require the secondary water temperature of each steam generator to be controlled within 25*F of the RCS cold leg temperature when starting a reactor coolant pump in a non-isolated loop.

Page B 3/4 4-la, Bases Section B 3/4.4.1 has been revised to reflect the above changes. This is more restrictive than the 50*F. value and is being submitted to support a future revision to the OPPS setpoint.

4. page 3/4 4-27a, Section 3.4.9.3, deleted Action statement "c" due to our proposed submittal in response to Generic Letter 83-43. We have deter-mined that reporting of PORV or RCS vent actuation to mitigate an overpressure transient will be required under Administrative Control 6.6.1 in accordance with 10 CFR 50.73.

5. page 3/4 5-7 has been removed from this change request since the changes that were proposed have been incorporated into the technical specifica-tions and are consistent with changes proposed herein.

6. page 3/4 5-7a, Section 3.5.4.1.2 and Section 4.5.4.1.2 have been re-worded to clarify the intent of the specification requirements.

7. page 3/4 4-2c, Section 3.4.1.3.c has been deleted. Our previous corre-spondence stipulated that during plant cooldown, one reactor coolant pump may be operated down to 160 F administrative 1y. Since this may not be possible under all cooldown conditions, this should not be required as a specification. The analysis for the original heat input case for overpressurization did not assume this limitation, but more correctly identified a maximum differential temperature limit between the primary and secondary coolants prior to starting a RCP.

Basis

1. Is the probability of an occurrence or the consequence of an accident or malfunction of equipment important to safety as previously evaluated in the UFSAR increased? No_

Reason:

The proposed changes incorporate additional administrative controls relative to the Overpressure Protection System installed at BV . The changes are canalstent with the UFSAR Section 4.2.2.7 description of the power operated relief valves low pressure setpoint. The changes are

O Safety Evaluation 1A-34 Page 4 being made to incorporate the administrative controls concerning the overpressure protection system, which are presently in affect in plant procedures, into the technical specifications.

2. Is the probability for an accident or malfunction of a different type than previously evaluated in the UFSAR created? N_oo Reason:

The proposed changes incorporate the administrative controls, which provide plant protection from pressure transients at low temperatures by reducing the probability of initiation of a transient and limiting the maximum pressure of such a transient to within the limits set by 10 CFR 50 Appendix G. Therefore, the changes will not create the possibility for a new type of accident or malfunction of a different type than evaluated in the UFSAR accident analysis of Section 14.

3. Is the margin of safety as defined in the basis for any Technical Specification reduced? No Reason The applicable technical specification bases include changes which address the revised limiting conditions f or operation and surveillance requirements. The addition of several .pecifications and additional requirements which provide for additional administrative controls are addressed in the bases, therefore, the changes incorporated in the bases will increase the margin of safety to an ovarpressure transient.

4. Based on the above, is an unreviewed safety question involved? M

5. Is a change to the UFSAR required? g Conclusion The proposed changes are administrative in nature. These additional administrative controls have been added to the technical specifications to provide additional protection from pressure transients at low temperatures by reducing the probability of initiation of a transient and by limiting the pressure of such a transient to below the limits set by 10 CFR 50 Appendix G.

The operational requirements of the overpressure protection system comply with General Design Criteria 15 and 31 and implement the guidelines of NUREG-0224 to provide protection from low temperature overpressure transients.

Based on the considerations above, the proposed changes have been determined to be safe and do not involve an unreviewed safety question.

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