ML20126D981

Proposed Tech Specs Allowing Use of Alternate SRMs as Long as Required CR & Containment Indications Available

ML20126D981
Person / Time
Site:	Beaver Valley
Issue date:	12/21/1992
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20126D955	List: ML20126D954 ML20126D969 ML20126D981
References
NUDOCS 9212280249
Download: ML20126D981 (20)

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DPR-66 gEFUELTNG OPERATIONS 3/4.9.2 INSTRUMENTATION

[jf,A,/yofa//g/pta/t) f LIMITING CONDITION FOR OPERATION-3.9.2 As a

minimum, two source range neutron flux monitorsAshall l

be operating, each with continuous visual indication in the control room and one with audible indication in the cpntainment apd control roomy, except dvei-uppet a}eten/s 1.idal/*}dn when one monite wiAl i

udnuous visuoi o do'ea h o, 11.o t conitol to+~ il et$4 *'.

APPLICABILITY:

MODE 6.

4 ACTION:

1 4,With the requirements of the above specification not satisfied, l

immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

The provision cf Opecificat-icn 2. 0. 2

+

-er; not applicable, i

b. Wib hok 6$e ched mondet.s m'oftto hlt. et Mo / of tto)h &gr >

de}eemine Ae-Loron conce hahi., of At hoche Coo /a.d fys.L, of least onee pee n Aou,u. SURVEILLANCE REQUIREMENTS i l 4.9.2 Each source range neutron flux monitor shall b'e j demonstrated OPERABLE by performance of: a. A CHANNEL FUNCTIONAL TEST at least once per 7 days, and b. A CHANNEL FUNCTIONAL TEST within 8 hours prior to the initial e. art of CORE ALTERATIONS, and c. A CHANNEL CHECK at least once per 12 hours during CORE ALTERATIONS. di 2 i O 4 BEAVER VALLEY - UNIT 1 3/4 9-2 PRoto.sEb 9212280249 921221 PDR ADOCK 05000334 p PDR --.--s ,.-m

DPR-66 3/4.9 REFUELING OPERATIONQ e BASES 3/4.9.1 BORON CONCENTRATION The limitations on minimum boron concentration (2000 ppm) ensure-that: 1) the reactor will_. remain-subcritical during-CORE ALTERATIONS, and

2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel.

The Limitation of Kaff of no greater than 0.95 which includes a conservative allowance -for uncertainties,. is sufficient to prevent reactor criticality during refueling operations. 3/4.9.2 INSTRUMENTATION The OPERABILITY-of.the source range neutron flux monitors ensures that redundant -monitoring capability _is available to detect changes in the reactivity condition of-the corapg j 3/4.9.3~ DECAY TIME The minimum requirement for reactor subcriticality prior to movement of irradiated fuel assemblies in the reactor vessel ensures that-sufficient time has elapsed to allow the radioactive decay of the short lived fission products. This decay _ time is consistent with the assumptions used in the accident analyses. 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS The requirements on containment penetration closure and operability of the containment purge and exhaust system HEPA filters and charcoal adsorbers -ensure that a release-of radioactive material within containment-will be restricted-from leakage to the environment or filtered _through the HEPA filters and charcoal adsorbers prior to discharge to the atmosphere within 10 CFR-100 limits. The OPERABILITY and closure restrictions are sufficient to restrict radioactive - material release from a fuel element rupture based upon the lack of containment pressurization potential while in the-REFUELING MODE. Operations of the containment purge and exhause system HEPA filters and charcoal adsorbers and the resulting iodine removal capacity are consistent with_the assumptions-of the-accident-analysis. when performing-those f volutions with the potential to initiate criticality. Suitable e b; detectors used in place of primary source range neutron flux monitors N-31 and N-32 are recognized as. alternate detectors.- Alternate detectors may-be used in place of primary source range neutron flux monitors.as long as -the required indication is provided. Since installation of the upper internals does.not involve movement of fuel or _a significant positive reactivity addition to the core, one; primary or alternate source range neutron flux ' monitor with continuous-visual indication in the control room provides-adequate-neutron flux monitoring capability during this evolution. BEAVER VALLEY - UNIT 1 B 3/4 9-1 MOPOSGb

l 1 i ATTACHMENT A-2 l ll Beaver Valley Power Station, Unit No. 2 Proposed Technical Specification Change No. 58 REVISED PAGES 1 j Revise the Technical Specification as follows: l Remove Paces Insert Pages 3/4 9-2 3/4 9-2 B 3/4 9-1 B 3/4 9-1 r i 1, i f l l l l l l l l l 4 1 \\ l 4 i l l I i

NPF-73 REFUELING OPERATIONS INSTRUMENTATION LIMITING CONDITION OF OPERATION h N 3.9,2 As a minimum, two source range neutron fl u vunitor shall be operating, l each with continuous visual indication in the contevi room and one with aud indicatiop in thq contr.inment and control room, exceg durig ugpu iWere z An dallattbn v) hen one monik ulid conlaurus vglsual,, caf,s.,,,; A con /rv/ roam 4 sep/ APPLICABILITY: MODE 6. 4 ACTION:

a. With the requirements of the above specification not satisfied, immediately l

suspend all operations involving CORE ALTERATIONS or positive reactivity changes. b.The rhk4 vi i Specificationbt.s'.0.3 are-act applicable. UNN e abovt noni apperable et nef opva}i?, dehn>*nt $t boten Conten&bh o.[ :NL Aeac.lW G/od Sys, tem as/ pct er SURVEILLANCE REQUIREMENTS ske /i Asu s f. 4.9.2 Each source range neutron flux monitor shall be demonstrated OPERABLE by performance of:- a. A CHANNEL FUNCTIONAL TEST at least once per 7 days, and b. A CHANNEL FUNCTIONAL TEST within 8 hours prior to the initial start of CORE ALTERATIONS, and c. A CHANNEL CHECK at least once per 12 hours during CORE ALTERATIONS. 4 t BEAVER VALLEY - UNIT 2 J/4 9-2 ffaibsfb

_ - ~ - NPF-73 3 / f.. O REFu! LING CPEaAT'ONS I 1 EASES 3/4.9.1 SCRCN CCNCENTRATICH The limitations on minimum boron concentration (2000 ppm) ensure that:

1) the reactor will remain suberitical during CORE ALTERATIONS, and 2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel.

The limitation on K of g7 no greater than 0.95 which includes a conservative allowance for uncertainties, is sufficient to prevent reactor criticality during refueling operations. Isolating all reactor water makeup paths from unborated water sources pre-cludes the possibility of an uncontrolled boron dilution of the filled portions of the Reactor Coolant Systes. This limitation is consistent with the initial conditions assumed in the accident analyses for MODE 6. 3/4.9.2 INSTRLMENTATION The OPERASILITY of the source range neutron flux monitors ensures that redundant menitoring capability is avallable to detect changes in the reactivity condition of the corejf when performing those 1 evolutions with the potential to initiate criticality. Suitable detectors used in place of primary source range neutron flux monitors N-31 and N-32 are recognized as alternate detectors. Alternate detectors may be used in place of primary source range neutron flux monitors as long as the required indication is provided. Since installation of the upper internals does not involve movement of fuel or a significant positive reactivity addition to tbs core, one primary or alternate source range neutron flux monitor with continuous visual indication in the control room provides adequate neutron flux monitoring capability during this evolution. 3/4.9.3 OECAY TIE The minimum requirement for reactor suberiticality prior to movement of irradiated fuel assemblies in the nector vessel ensures that sufficient time has elapsed to allow the radioactive decay of the short lived fission.. products. This, decay time is consistant with the assumptions used'in the accident analyses. 3/4.9.4 C0dTAIWWff BUILDING PENETRATIONS The requirements on containment penetration closure limit leakage of radio-active material within containment to the environment to ensure compliance with 10 CFR 100 limits. The requirements on operation of the SLCRS ensure that trace amounts of radieective asterial within containment will be filtered through HEPA filters charcoal absorbers prior to discharge to the atmosphere. These require-ments are sufficient to restrict radioactive material misase from a fuel element rupture based upon the lack of containment pressurization potential while in the REFUELING M00E. 3/4.9.5 COMUNICATIONS The requirements for communications capability ensures that refueling l station personnel can be promptly informed of significant changes in the facility status or core reactivity conditions during CORE ALTERATIONS. Beaver Valley - Unit 2 8 3/4 9-1 PM NsED

ATTACHMENT B Beaver Valley Power Station, Unit Hos. 1 and 2 Proposed Technical Specification Change No. 193/58 ) REVISION OF TECHNICAL SPECIFICATION 3.9.2 ALTERNATE SOURCE RANGE DETECTORS A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would modify the source range requirements to provide for alternate monitors. This change incorporates two important features (1) allows the use of alternate monitors as long as the required visual and audible indications are available, and (2) allows installation of the upper internals when only one monitor with continuous visual indication in the control room is available. In

addition, the current action statement has been identified as Action "a",

and Action "b" has been added to apply when both monitors are inoperable, therefore, the exception to Specification 3.0.3 is no longer required and has been deleted. B. BACKGROUND The proposed changes are requested to eliminate future temporary waivers of compliance (TWOC) or emergency technical specification changes in the event a source range monitor becomes inoperable. During the BV-1 Cycle 8 refueling outage, all the fuel had been removed from the reactor vessel and just prior to reinsertion of the fuel a source range monitor was declared inoperable. Replacing the monitor was not practical due to the high radiation field creatad while the incore flux thimbles were withdrawn from the reactor

vessel, therefore, a regional TWOC was requested to allow use of an alternate monitor.

C. JUSTIFICATION The proposed changes incorporate requirements similar to those described in other plant's technical specifications (i.e., Turkey Point Units 3 and 4, Hope Creek, Browns Ferry Unit 2 and Vermont Yankee). These changes will not affect the reactivity of the

core, only the detector used to monitor core reactivity.

The required shutdown margin will continue to be maintained and the source range monitors will continue to provide the required visual indication in the control room along with audible indication in the containment and the control room. The alternate monitors may be either installed spare detectors or portable monitors with sufficient sensitivity to adequately monitor reactivity changes in the core during refueling operations. Action Statement "b" is censistent with the Standard Technical Specifications (STS) ar.d eliminates the requirement for an exception to Specification 3.0.3. D. SAFETY ANALYSIS Specification 3.9.2 has been revised to permit alternate monitors in place of primary source range neutron flux monitors. The alternate monitor (s) may be either an installed spare detector or a portable monitor with the accuracy and sensitivity required to

- ~. -. ATTACllMENT B, continued Proposed Technical Specification Change Nos. 193/58 Page 2 adequately monitor changes in the core reactivity condition during refueling activities. The alternate monitor (s) will be connected to provide the required indications in the control room and or containment. The refueling sequence may be altered slightly by placing a source-bearing assembly near the alternate detector location to ensure an adequate count rate is maintained. The alternate monitors will provide neutron flux monitoring in place of primary source range monitors thus assuring core monitoring at a level consistent with the current technical specification requirements. Therefore, there is no loss of function or need for additional compensatory actions and the refueling evolutions can be continued while relying on the alternate monitors. l Two operable monitors are required when in Mode 6. This provides redundancy during fuel movement and evolutions that may affect positive reactivity

changes, including upper internals removal.

Fuel movement and positive reactivity additions can significantly affect the reactivity condition of the

core, therefore, two monitors are required operable during these evolutions.

Removal + of the upper internals could affect a positive reactivity addition if a control rod drive shaft became stuck in the upper internals and when lifted would pull the control rod from a fuel assembly. Pulling a single control rod would not cause a significant reactivity transient due to the small. amount of 1 i reactivity associated with each individual control rod and the large amount of negative reactivity provided in accordance with Specification 3.9.1 where the reactor coolant system boron concentration is maintained greater than 2000 ppm. However, to assure detection of an increase in count rate in the case of a multiple control rod lift,. redundant' source range monitors are required to be operable. The function of the source range monitor is to provide direct neutron flux monitoring of the core i to detect changes in reactivity which would result in a loss of the required shutdown margin. One monitor will provide continuous visual and audible indication in the containment and control-room while the redundant monitor will provide continuous visual indication in the control room. These changes provide those indications consistent with the current technical specification requirements where at least two source range monitors are operating -and capable of providing the required control room indications, one primary or alternate monitor would be required during installation of the upper internals. Installation of the upper internals acts to reflect neutrons back into the core which is recognized as a positive' reactivity

addition, however, this reactivity addition is sufficiently. small when compared to the negative reactivity provided by the required' shutdown margin that the effect is negligible and is accounted for in the shutdown margin calculations.

The shutdown margin remains essentially unchanged and will be available to preclude a criticality event during this evolution. Inadvertent control rod withdrawal is not a concern during upper internals installation, therefore, one a

ATTACHMENT B, continued 1 Proposed Technical Specification Change Nos. 193/58 Page 3 primary or alternate source range monitor can adequately monitor the core neutron flux during this evolution. Action "b" has been added to address the condition where both source range _ monitors are inoperable or not operating. This 1 additional action is consistent with the STS and eliminates the need for an exception to Specification 3.0.3. Bases 3/4.9.2, Instrumentation, has been revised to include the changes to Specification 3.9.2 concerning alternate source range monitors and the number of monitors required operable in Mode 6. 4 The alternate monitors may be either installed spare detectors or i portable monitors with sufficient sensitivity to adequately monitor reactivity changes in the core during refueling operations. Core alterations or positive reactivity changes which could lead to core criticality require redundant source j range monitoring to ensure adequate indication is available for the control room operators to recognize a potential event and oct to mitigate the consequences. Installing the upper internals-does not involve movement of fuel or represent a significant positive reactivity addition to the core. Therefore, redundant source range monitoring is not required during this evolution. The proposed changes do not affect the UFSAR system description or accident analyses. The operability requirements of Specification 3.9.2 will continue to be met when using an i alternate monitor in place of a source range neutron flux monitor. No changes are being incorporated that would act ta increase the probability of a positive reactivity addition event, therefore, the proposed changes are considereu 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 i 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: (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of l accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety, i The following evaluation is provided for the no significant hazards consideration standards.

ATTACHMENT B, continued Proposed Technical Specifict'.'i Change Nos.- 193/58 ) Page 4 1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated? The proposed amendment would modify Specification 3.9.2 to permit the use of alternate monitor (s) in place of inoperable source range monitor (s). The alternate monitors will be connected to provide the required' indications in the control room and or containment. The alternate monitors may be either an installed spare detector or a portable monitor with the accuracy and sensitivity required to adequately monitor changes in the core reactivity levels during refueling activities. The refueling sequence may be altered slightly by placing a source-bearing assembly near the alternate detector location to ensure an adequate count rate is maintained. 4 The alternate monitor (s) will provide neutron flux monitoring in place of primary source range monitors thus assuring core monitoring at a level consistent with the current technical specification requirements.- Therefore, there is no loss of function or need for additional compensatory actions and the refueling evolutions can be i continued while relying on the alternate-monitors. Two operable monitors are required during fuel movement and 3 evolutions that could potentially cause positive reactivity changes. Fuel movement and positive reactivity additions can significantly affect the reactivity condition of the

core, therefore, two monitors are required operable during these evolutions.

Redundant detectors are required to ensure that two source range neutron flux monitors are availabic to detect changes in core reactivity. Removal of the upper internals could affect a positive reactivity addi ion if a control rod drive shaft became stuck in the upper internals and was subsequently lifted which would pull l the control rod from a fuel assembly. Pulling a single control rod would not cause a significant reactivity transient due to the small amount of reactivity associated with each individual control rod and the large amount of negative reactivity-provided in accordance with j Specification 3.9.1 where the rez.ctor coolant system boron ~ concentration is maintained greater than 2000 ppm.

However, to assure detection of a potential criticality event in the case of a multiple control rod lift, redundant source range monitors are - required to be operable.

One monitor will proviJe continuous visual and audible indication in the containment and control room while the redundant monitor will provide continuous visual indication in the control room. These changes provide those indications consistent with the current technical specification requirements where at least two source range monitors are operating and capable of providing the required control room indications. The function of the source range monitors is to provide direct

= _. _. _ _ _ _ _ _ ___ _ _ ATTACHMENT B, continued Proposed Technical Specification Chango Nos. 193/58 Page 5 4 neutron flux monitoring of the core to detect changes in reactivity which would result in a loss of the required shutdown margin. I One primary or alternate monitor would be required during installation of the upper internals. Installation of the 3 upper internals acts to reflect neutrons back into the core 1 which is recognized as a positive reactivity

addition, however, this reactivity addition is sufficiently small when j

compared to the negative reactivity provided by the required shutdown margin that the effect is negligible and is accounted for in the shutdown -margin' calculations. The shutdown margin remains essentially unchanged and will be available to preclude a.-criticality event during this evolution. Inadvertent control rod-withdrawal is not a i concern during upper internal installation, therefore, one j primary or alternate source range monitor can adequately monitor the core neutron flux during this. evolution. J Action "b" has been added to address the condition where both source range monitors are inoperable or not operating. This additional action is consistent with the STS and eliminates the need for an exception to Specification 3.0.3. Bases 3/4.9.2, Instrumentation, has been revised to include 4 the changes to Specification 3.9.2 concerning alternate sourco range monitors and the number of monitors required operable during Mode 6. The alternate monitors may be either installed spare detectors or portable monitors with sufficient sensitivity to adequately monitor-reactivity changes in the core during refueling operations. Core alterations or positive reactivity changes which could lead to core criticality require redundant source range monitoring to ensure adequate indication is available for the control _ room operators to recognize a potential-event and act to mitigate.the consequences. Installing the upper internals does not involve movement of fuel or represent a significant positive reactivity addition to the core. ] Therefore, redundant source range monitoring is not required during this evolution. The operability requirements of Specification 3.9.2 will ] continue to be met when using an alternate monitor in place of a source range neutron flux monitor. No changes are being incorporated that would act to increase' the probability of a positive reactivity addition

event, therefore, the proposed changes.

will not involve-a significant increase in the probability or consequences of an accident previously evaluated. 2. Does the change create the possibility of a new or different j kind of accident from any accident previously evaluated? The function of the source range detectors is to provide direct neutron flux monitoring of the core to detect

ATTACHMENT B, continued Proposed Technical Specification Change Nos. 193/58 Page 6 positive reactivity additions which would result in a loss of the required shutdown margin. The alternate monitors may be either an installed spare detector or a portable monitor with the accuracy and sensitivity required to adequately monitor changes in the core reactivity levels during refueling activities. The alternate monitors will be connected to provide the required indications in the control room and or containment. Therefore, there is no loss of function or need for additional compensatory actions-and the refueling evolutions can be continued while relying on the alternate monitors. Redundant monitors 'are required operable during those evolutions which could lead to criticality. This is consistent with the current technical specification requirements since with one inoperable monitor the action statement requires suspension of all operations involving core alterations or positive reactivity changes. These changes are. similar to changes incorporated by other plants and will not affect the reliability of the source range instrumentation to provide the required indications. Therefore, the proposed changes will not create-the possibility of a new or different kind of accident from any accident previously evaluated. t 3. Does the change involve a significant reduction in a margin of safety? I The proposed changes will continue to ensure the required source range instrumentation functions are available during refueling operations. These changes will not reduce the reliability of the source range detectors to monitor the core reactivity condition and provide the appropriate control room and containment indications or affect the required shutdown margin. Plant operation will continue to be maintained within the shutdown margin requirements of Specification 3.9.1. The required visual and audible indications are still maintained in accordance with current technical specification requirements and the shutdown margin is unaffected, therefore, the proposed changes will 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 _SO.92(c)

and, accordingly, a

no significant hazards consideration finding is justified.

i

} i ATTACHMENT C-1 Beaver Valley Power Station, Unit No. 1 Proposed Technical Specification Change No. 193 i TYPED REVISED PAGES l 1i i Typed Pages: i j 3/4 9-2 B 3/4 9-1 1 l l l l { 1 i l

DPR REFUELING OPERATIOUH 3/4.9.2 INSTRUMENTATION LIMITING CONDITION FOR OPERATION 4 3.9.2 As a minimum, two source range neutron flux monitors (primary I or alternate) shall be operating, each with continuous visual indication in the control room and one with audible indication in the containment and control

room, except during upper internals installation when one monitor with continuous visual indication in the control room is required.

APPLICABILITY: MODE 6 ACTION: a. With the requirements of the above specification not satisfied,. I immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes, b. With both of the above monitors inoperable or not operating, determine the boron concentration of the Reactor Coolant System at least once per 12 hours, i SURVEILLANCE REQUIREMENTS 4.9.2 Each source range neutron flux monitor shall be demonstrated OPERABLE by performance of: I a. A CHANNEL FUNCTIONAL TEST at least once per 7 days, and b. A CHANNEL FUNCTIONAL TEST within 8 hours prior to the initial start of CORE ALTERATIONS, and' l c. A CHANNEL CHECK at least once per 12 hours during CORE l ALTERATIONS. l I BEAVER VALLEY - UNIT 1 3/4 9-2 Amendment No. PROPOSED

DPR-66 3 /4. 9 REFUELING OPERATLQEE l 1 BASES 3/4.9.1 BORON CONCENTRATION The limitations on minimum-boron _ concentration (2000 ppm) ensure that:

1) the reactor-will remain subcritical during-CORE' ALTERATIONS, and 2) a uniform boron concentration is maintained for-reactivity control in the water volume having direct access to the reactor vessel.

The limitation of K of no greater than 0.95 which eff includes a conservative allowance for uncertainties, is sufficient to prevent reactor criticality during refueling operations. 3/4.9.2 INSTRUMENTATION The OPERABILITY of the source range' neutron flux ~ monitors ensures that redundant monitoring capability is available to detect-changes in the reactivity condition of the_ core when-performing those evolutions with~ the potential to initiate-criticality. Suitable detectors used in place of primary source range neutron flux monitors N-31 and N-32 are recognized as alternate detectors. Alternate detectors may be used in place of primary source range-neutron flux monitors as long as the -required - indication is provided. 'Since installation of.the upper internals does not' involve movement of fuel or a significant positive reactivity addition to the core, one primary or alternate source range neutron. flux monitor with continuous-visual indication in the-control room provides adequate neutron flux monitoring capability during this evolution. 3/4.9.3 DECAY TIME The minimum requirement for reactor subcriticality prior to movement of irradiated fuel assemblies in the reactor vessel ensures that sufficient time has elapsed to allow the radioactive decay-of the short lived fission products.. This. decay _ time is consistent with the-assumptions used in the accident analyses. 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS 1 i The requirements-on containment penetration closure and operability of. the containment purge and exhaust system HEPA filters-and-charcoal adsorbers ensure that a release of radioactive material' within containment will be restricted from leakage:to the environment or filtered through the HEPA filters and charcoal adsorbers prior to discharge to the atmosphere within 10_.CFR 100 limits. The OPERABILITY and closure restrictions are sufficient'1to restrict radioactive material release from a~ fuel element: rupture based upon the lack of containment pressurization potential Lwhile in the REFUELING MODE. Operations of-the. containment: purge and exhaust system-HEPA filters and charcoal.adsorbers and:the resulting-iodine removal capacity are consistent with the assumptions of the accident analysis. BEAVER VALLEY - UNIT 1 B 3/4 9-1 Amendment No. PROPOSED .~

1 i ATTACHMEllT C-2 s i, Beaver Valley Power Station, Unit 11o. 2 l Proposed Technical Specification Change lio. 58 i j TYPED REVISED PAGES i l Typed Pages: i l 3/4 9-2 B 3/4 9-1 B 3/4 9-2 B 3/4 9-3 l B 3/4 9-4 i I l

NP.F-73. REFUELING OPERATIONS 2/4.9.2 INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.9.2 As a minimum, two source range neutron flux monitors (primary or alternate) shall be operating, each with continuous visual indication in the control room and one with audible indication in the containment and control

room, except during upper internals installation when one monitor with continuous visual indication in 3

the control room ir aquired. APPLICABILITY: MODE 6 2 ACTION: a. With the requirements of the above specification not satisfied, l immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes. b. With both of the above monitors inoperable or not operating, determine the boron concentration of the Reactor Coolant System at least once per 12 hours. SURVEILLANCE REQUIREMENTS 4.9.2 Each source range neutron flux monitor shall be demonstrated OPERABLE by performance of: a. A CHANNEL FUNCTIONAL TEST at least once per 7 days, and b. A CHANNEL FUNCTIONAL TFST _within 8 hours prior to the initial start of CORE ALTERATIONS, and c. A CHANNEL CHECK at least once per 12 hours during CORE ALTERATIONS. l i BEAVER VALLEY - UNIT 2 3/4 9-2 Amendment No. PROPOSED

4 NPF-73. 3/4.9 REFUELING OPERATIONS BASES 1/4.9.1 BORON CONCENTRATION The limitations on minimum boron concentration (2000 ppm) ensure that:

1) the reactor will remain subcritical during CORE ALTERATIONS, and 2) a uniform boron concentration is maintained for reactivity control in the water volume having direct access to the reactor vessel.

The limitation of K of no greater than 0.95 which eff includes a conservative allowance fcnr uncertainties, is sufficient to prevent reactor criticality during refueling operations. Isolating all reactor water makup paths from unborated water sources precludes the possibility of an uncontrolled boron dilution of the filled portions of the Reactor Coolant System. This limitation is consistent with the initial conditions assumed in the accident analyses for MODE 6. 3/4.9.2 INSTRUMENTATION The OPERABILITY of the source range neutron flux monitors ensures i that redundant monitoring capability is available to detect changes in the reactivity condition of the core when performing those evolutions with the potential to initiate criticality. Suitable detectors used in place of primary source range neutron flux monitors N-31 and N-32 are recognized as alternate detectors. Alternate detectors may be used in place of primary source range neutron flux monitors as long as the required indication is provided. Since installation of the upper internals does not involve movement of fuel or a significant positive reactivity addition to the core, one primary or alternate source range neutron flux monitor with continuous visual indication in the control room provides adequate neutron flux monitoring capability during this evolution. 3/4.9.3 DECAY TIME The minimum requirement for reactor subcriticality prior to movement of irradiated fuel assemblies in the reactor vessel ensures that sufficient time has elapsed to allow the radioactive decay of the short lived fission products. This decay time is consistent with the assumptions used in the accident analyses. BEAVER VALLEY - UNIT 2 B 3/4 9-1 Amendment No. PROPOSED

NPF-73. ~ i REFUELING OPERATIONS BASES .= 3/4.9.4 CONTAINMENT BUILDING PENETRATIONS The requirements on containment penetration closure limit leakage of radioactive material within containment to the environment to ensure compliance with 10 CFR 100 limits. The requirements on operation of the SLCRS ensure that trace amounts of radioactive material within containment will be filtered through HEPA filters charcoal adsorbers prior to discharge to the atmosphere. These requirements are sufficient to restrict radioactive material release from a fuel element rupture based upon the lack of containment pressurization potential while in the REFUELING MODE. 3/4.9.5 COMMUNICATIONS The requirements for communications capability ensures that refueling station personnel can be promptly informed of significant changes in the facility status or core reactivity conditions during CORE ALTERATIONS. 3/4.9.6 MANIPULATOR CRAME OPERABILITY The OPERABILITY requirements for the manipulator cranes ensure that: 1) manipulator cranes will be used for movement of control rods and fuel assemblies; 2) each crane has sufficient load capacity to lift a control rod or fuel assembly; and 3) the core internals and pressure vessel are protected from excessive lifting force in the event they are inadvertently engaged during lifting operations. 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE BUILDING The restriction on movement of loads ir. excess of the normal weight of a fuel assembly over other fuel assemblies ensures;that no more than the contents of one fuel assembly'plus an additional 50 rods in the stuck fuel assembly will be ruptured in the event of a fuel handling accident. This assumption is consistent with the activity release assumed in the accident analyses. 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION The requirement that at least one residual heat removal (RHR) loop be in operation ensures that 1) sufficient cooling capacity is available to remove decay heat and maintain the water in the reactor-pressure vessel below 140*F as required during the REFUELING MODE, and 2) sufficient coolant circulation is maintained throughout the-reactor core to minimize the erfect of a boron dilution incident and prevent boron stratification. BEAVER VALLEY - UNIT 2 B 3/4 9-2 Amendment No. PROPOSED

NPF-73. REFUELING OPERATIONS 1 BASES a 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT CIRCULATION (continued) The requirement to have two RHR loops OPERABLE when there is less than 23 feet of water above the reactor pressure vessel flange ensures that a single failure of the operating RHR loop will not result in a complete loss of residual heat removal capability. With r the reactor vessel head removed and 23 feet of water above the reactor pressure vessel flange, a large heat sink is available for core cooling. Thus, in the event of a failure of the operating RHR

loop, adequate time is provided to initiate emergency procedures to cool the core.

l 3/4.9.9 CONTAINMENT PURGE AND EXHAUST ISOLATION SYSTEM The OPERABILITY of this system ensures that the containment vent and purge penetrations will be automatically isolated upon detection of high radiation levels within the containment. The integrity of the containment penetrations of this system is required to meet 10 CFR 100 requirements in the event of a fuel handling accident inside containment. Applicability in MODE 5, although not an NRC safety requirement, will provide additional protection against small releases of radioactive material from the containment during maintenance activities. 3/4.9.10 AND 3/4,9.11 WATER LEVEL - REACTOR VESSEL AND STORAGE POOL The restrictions on minimum water level ensure that sufficient water depth is available to remove 99% of the assumed 10% iodine gap activity released from the rupture of an irradiated fuel assembly. The minimum water depth is consistent with the assumptions of the accident analysis, i ( 3/4.9.12 and 3/4.9.13 FUEL BUILDING VENTILATION SYSTEM The limitations on the storage pool ventilation system ensure that all radioactive material released from an irradiated fuel assembly will be filtered through the HEPA filters and charcoal adsorber prior to discharge to the atmosphere. The OPERABILITY of this system and the resulting iodine removal capacity are consistent with the assumptions of the accident analysis. The spent fuel pool area ventilation system is non-safety related and only recirculates air through the fuel building. The fuel building portion of the SLCRS is safety related and continuously filters the fuel building exhaust air. This maintains a negative pressure in the fuel building. BEAVER VALLEY - UNIT 2 B 3/4 9-3 Amendment No. PROPOSED

. - ~ -.. - - - -. NPF-73 REFUELING OPERATIONS BASES i 3/4.9.14 FUEL STORAGE - SPENT FUEL STORAGE POOL i I The requirements for fuel storage in the_ spent fuel-pool' ensure: that: _ (1) the spent fuel pool will remain subcritical during fuel 1 storage ;-- and (2) a uniform boron concentration is maintained in the j water volume in the spent fuel pool.to provide negative reactivity for postulated accident conditions _under the guidelines of ANSI 16.1-1975. The-value of 0.95 or less for K f which-includes all uncertainties at.the 95/95 probability / conf! bence level is the [ acceptance criteria for fuel storage in the spent fuel pool.- 1 l-Verification that peak fuel ~tod~burnup is less than 60 GWD/MTU is provided in the reload evaluation-report associated'with each fuel cycle. - -applicable txr fuel storage in the spent The Action Statement fuel pool ensures that: (1) the spent _ fuel pool is protected from i distortion in the fuel storage -pattern - that could-resultLin a critical array during the movement of fuel; and. (2) the boron-concentration is maintained at 2 1050 ppm (this includes a 50 ppm conservative allowance for uncertainties) during all _ actions involving movement of fuel in the spent fuel pool. i The Surveillance-Requirements applicable to fuel' storage in the j spent fuel pool ensure that: (1) the fuel _ assemblies satisfy the analyzed U-235 enrichment limits or an analysis has been performed and it was determined that K is 5 0.95; and-(2) tho_ boron j concentration meets the 1050 ppm $gg1mit. l \\ l l i l' 1 BEAVER VALLEY'- UNIT 2-B 3/4-9-4 Amendment No. - l PROPOSED l 5 v ,e-. - 3 ,j- ..n g -,...-r- ..-m... .a.e-.,,y- .}}