ML20199F305
| ML20199F305 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 01/20/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20199F298 | List: |
| References | |
| GL-93-08, GL-93-8, NUDOCS 9802030128 | |
| Download: ML20199F305 (4) | |
Text
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t UNITED STATES s-Q' NUCLEAR REGULATORY COMMISSION-(
WASHINGTON, D.C. speeHoot
~ SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ANrunNENT Nos. 210-AND 88 TO FACILITY OPERATING LICENSE NDS. DPR-66 AIN) NPF-73 DUQUESNE LIGHT COMPANY GH10 EDIS0N C(MPANY PENNSYLVANIA p0WER C(MPANY TP.E CLEVELAND ELFCTRIC ILLtMINATING C(MPANY THE T0 LED 0 FDISON COMPANY BEAVER-VALLEY F0WER STATION. UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412
1.0 INTRODUCTION
By letter dated September 11, 1997, the Duquesne Light Company (the licensee)
. submitted a request for changes to the Beever Valley Power Station, Unit Nos.
I and 2 changes w(BVPS-1 and BVPS-2), Technical Specifications (TSs). The requested ould relocate the reactor trip system (RTS) and engineered safety feature actuation system (ESFAS) response times from TS Tables 3.3-2 and 3.3-5 to Section 3 of the Licensing Requirements Manual (LRM). The LRM would be an
-appendix to tha Updated Final Safety Analysis Report (UFSAR). Neither'the response time limits nor the surveillance requirements for performing response time testing would be altered by these proposed changes. Any future changes to the LRMs will be controlled in accordance with the requirements of 10 CFR 50.59. The proposed amendments would also make several editorial changes in TSs 3.3.1.1 and 3.3.1.2, as well as s king conforming changer to the Bases for these TSs.
2.0 BACKEROUND Section 182a of the Atomic Energy Act (the "Act") requires applicants for nucles.r power plant operating licenses to include TSs as part of the license.
The Commission's regulatory requirements related to the content of TSs are set forth in 10 CFR 50.36. That regulation requires that the TSs include items in five specific categories, including (1) safety limits, limiting safety system settings and-limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. The regulation, however, does not specify the particular requirements to be included'in the plant TSs.
9802030128 980120 PDR ADOCK 05000334 P
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-t-The four criteria defined by 10 CFR 50.36 for determining whether particular limiting conditions for operation are required to be inc uded in t w TSs, are as-follows:
(1) installed instrumentation that is used to detect, and
-indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary;- (2) a process variab e, design feature, or' operating restriction that is an-in4tial condition of a design basis _ accident or trans'ent-analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a-fission product barrier; (4) a structure, system, or component wh' ch operating experience or probabilist9c safety assessment has shown to be significant to public health an't safety.
Existing TS limiting conditions for operation which do not satisfy these four specified criteria may be relocated to the UFSAR, such that future changes could be made to these provisions pursuant to 10 CFR 50.59. Other e
requirements may be relocated to more appropriate documents (e.g. Security
- Plan, Quality Assurance plan, and Emergency Plan) and controlled by the applicable regulatory requirement.
3.0 EVALUATION NRC Generic Letter (GL) 93-08, " Relocation of Technical Specification Tables of Instrument Response Time Limits," dated December 29,:1993, provides guidance to licensees proposing to relocate RTS and ESFAS instrument response
. time limits from the TSs to the UFSAR. GL 93-08 provides that relocation of the RTS and ESFAS instrument response time limits from-the TSs to the UFSAR should not alter the-surveillance requirements. After relocation, the UFSAR should contain the response time limits for the RTS and ESFAS instruments, including those channels for which the response time limit is indicated as "NA"; that is, a response time is not applicable. The UFSAR should also clarify response-time limits where footnotes are included in the tables that describe how those limits are applied. The limiting condition for operation (LCO) for the RTS and ESFAS instruments should be modified to delete the phases "with RESPONSE TIMES as shown in Tabit 3.3-2 (RTS) or 3.3-5 (ESFAS)" so as.to simply state that this instrumentation 'shall be OPERABLE." Although the surveillance requirements for the RTS and CSFAS instrument response time limits do not reference the tables containing these. limits and therefore do not need to be modified to implement this change, a footnote on TS Table 3.3-2 states that neutron detectors are exempt from response time testing. To retain this exception, which is stated in TS Table 3.3-2 (being removed from the TSs by this amendment), the RTS surveillance requirements should be modified to add the following statement:
" Neutron detectors are exempt from response time testing."
-The licensee's proposed changes would relocate the RTS and ESFAS instrument response time limits from the TSs to the LRM, which would become an appendix to the UFSAR, would not alter the surveillances for these instruments or
, change any of the response time limits, including those channels for which the response time limit is indicated as NA. The clarifications provided in the applicable TS footnotes describing how the response time limits are to be applied will also be relocated to the LRM. The licensee stated that any future changes to the RTS and ESFAS instrument response time limits will be performed in accordance with the requirements of 10 CFR 50.59. The licensee's proposed changes would also delete from the LC0, the phrase 'with response TIMES as shown in Table 3.3-2 (RTS) or 3.3-5 ESFAS)" so as to simply state
'shall be OPERABLE." The surveillance recuirements for the RTS would be revised to include the footnote " Neutron cetectors are exempt from response time testing," which was previously included on TS Table 3.3-2.
These-proposed changes are consistent with the guidance provided in GL 93-08 and are, therefore, acceptable.
Additionally, several editorial changes which do not affect the intent of the TSs would be made. These changes are also acceptable since they do not change the requirements of the TSs.
Although not included in the September 11, 1997, submittal, the licensee provided a revised BVPS-1 TS Index page XVI for inclusion in this amendment.
Index page 7.'!! shows the deletion of TS Table 3.3-2 and 3.3-5.
These deletions are appropriate and acceptable since TS Table 3.3-2 and 3.3-5 are being deleted from the BVPS-1 TSs by this amendment.. Also included in this amendment and acceptable, but not included in the September 11, 1997, submittal is a correction to BVPS-2 TS page 3/4 3-14 to provide the proper designation of BVPS-2 TS Table 3.3-3 (rather than 3.3.3) and the reissuance of BVPS-2 TS pages B 3/4 3-3 and B 3/4 3-4 due to repagination of material previously on TS pages B 3/4 3-2, 8 3/4 3-3, and B 3/4 3-4.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official-had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments-involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (62 FR 54871). Accordingly, the amendments meet the eligibility criteria for
. categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the 1,;suance of the amendments, s
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
public w(1) there is reasonable assurance that the health and safety of the ill not be endangerad by operation in the proposed manner, activities will be conducted in compliance with the Commission's reg (2) such
- ulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Princtpal Contributor:
D. Brinkman Date: January 20, 1998 t.
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