ML20204E438

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Proposed Tech Specs Bases Section 3/4.7.13,adding Wording Which Discusses Design Bases of Sys in Greater Depth
ML20204E438
Person / Time
Site: Beaver Valley
Issue date: 03/16/1999
From:
DUQUESNE LIGHT CO.
To:
Shared Package
ML20204E435 List:
References
NUDOCS 9903250035
Download: ML20204E438 (11)


Text

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a ATTACHMENT A-1 Beaver Valley Power Station, Unit No. 1 License Amendment Request No. 264 The following is a list of the affected page:

1 Affected Page: B 3/4 7-7 i

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1 9903250035 990316

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PDR ADOCK 05000334 P PDR ..

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@tg-Cgd- Acc PLANT SYSTEMS BASES '

3/4.7.13 AUYILIARY RIVER WATER SYSTEM _p IkNWb The operability of the ARWS ensures that sufficient cooling capacity is available to bring the reactor to a cold shutdown condition in the event that a barge explosion at the station's intake structure or other- extremoly remote event would render all of the normal Wg gg Qg g supply pumps inoperable.

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i BEAVER VALLEY - UNIT 1 B 3/4 7-7 Amendment No.% i;;-

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AttachInt A-1 Beaver Valley Power StLtion, Unit No. 1 l

-License Amendment Reauest No. 264 INSERT "A" _

i The scenario of a postulated gasoline barge ' impact with the intake {

structure and coincident explosion disabling the Reactor Plant River Water System (RPRWS) is a low probability event and is outside those typically. postulated by the NRC for reactor sites. Nonetheless, the ARWS provides defense in-depth in_ assuring shutdown cooling j capability. The requirement to operate the ARWS is not coincident '

with a postulated Design Basis Accident, but only for the postulated gasoline barge impact event. ]l Although the ARWS is a manually operated non-safety system which is not required to meet- single active failure criteria, the system is designed with redundant pumps and valves on a header to accommodate  ;

a single active failure on start-up. Thic design criteria provides a l defense in-depth in order to ensure the system can adequately  !

mitigate the consequences of the postulated event. An ARWS pump can j be manually started on the emergency bus during loss of offsite power '

after the diesel loading sequence is complete. If.there is a delay in~ starting.the ARWS, the auxiliary feedwater system is available to remove reactor core decay heat for a short term period.

1 The ' requirements for subsystem OPERABILITY are similar to those of l' the RPRWS except that one subsystem is required to be OPERABLE in the MODES noted. The Limiting Condition for Operation reflects the low {

risk of the postulated event compared to more stringant requirements J associated with safety related systems. The ACTION statement takes ;

into account the low probability of both trains of RPRWS being l disabled as a result of the postulated site scenario coincident with I one of the ARWS subsystems being OPERABLE. l BEAVER VALLEY - UNIT 1 (Proposed Wording)

l ATTACHMENT A-2 Beaver Valley Power Station, Unit No. 2 License Amendment Request No. 139 The following is a list of the affected pages:

Affected Pages: XII B 3/4 7-6 s

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. LEDCE BASES SECTION PAGE 3/4.7.4 . SERVICE WATER SYSTEM. . . . . . . . . . . . B 3/4 7-3 l 3/4.7.5 ULTIMATE HEAT SINK. . . . . . . . . . . . . B 3/4 7-3 3/4.7.6 FLOOD PROTECTION. . . . . . . . . . . . . . B 3/4 7-4 i

i 3/4.7.7 CONTROL ROOM EMERGENCY AIR CLEANUP AND PRESSURIZATION SYSTEM . . . . . . . . . . . B 3/4 7-4 3/4.7.8 SUPPLEMENTAL LEAK COLLECTION AND RELEASE SYSTEM (SLCRS). . . . . . . . . . . . . . . B 3/4 7-4 3/4'7.9

. SEALED. SOURCE CONTAMINATION . . . . . . . . B 3/4 7-5 3/4.7.12 SNUBBERS. . . . . . . . . . . . . . . . . . B 3/4 7-5 3/4.7.13 STANDBY SERVICE WATER SYSTEM (SWE) . . . . . B 3/4 7 3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES. . . . . . . . . . . . . . . . B 3/4 8-1 3/4.8.2 ONSITE POWER DISTRIBUTION SYSTEMS . . . . . B 3/4 8-1 3/4.9 REFUELING OPERATIONS 3/4.9.1 BORON CONCENTRATION ... . . . . . . . . . . B 3/4 9-1 3/4.9.2 INSTRUMENTATION . . . . . . . . . . . .. . . B 3/4 9-1 3/4.9.3 DECAY TIME. . . . . . . . . . . . . . . . . B 3/4 9-1 3/4.9.4 CONTAINMENT B'UILDING PENETRATIONS . . . . . B 3/4 9-1 1

3/4.9.5 COMMUNICATIONS. . . . . . . . . . . . . . . B 3/4 9-2 3/4.9.6 MANIPULATOR CPANE OPERABILITY . . . . . . . B 3/4 9-2 3/4.9.7 CRANE TRAVEL - SPENT FUEL STORAGE BUILDING. B 3/4 9-2 3/4.9.8 RESIDUAL HEAT REMOVAL AND COOLANT I CIRCULATION . . . . . . . . . . . . . . . . B 3/4 9-2 )

i 3/4.9.9 CONTAINMENT PURGE AND EXHAUST ISOLATION l SYSTEM. . . . . . . . . . . . . . . . . . . B 3/4 9-3 i

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3/4.9.10 AND 3/4.9.11 WATER LEVEL-REACTOR VESSEL AND I STORAGE POOL . . . . . . . . . . . . . . . B 3/4 9-3 l 1

BEAVER VALLEY - UNIT 2 XII Amendment No. 40-(,fre d ldo

SNUBBERS (Continued) l inservice functional testing, that snubber may be exempted from being counted as inoperable. Generically susceptible snubbers are those which .are of a Cpecific make or model and have the same design features directly related to rejection of the snubber by visual inspection, .or are similarly located or exposed to the same environmental conditions such as temperature, radiation and vibration.

When a snubber is found inoperable, an engineering evaluation is performed, in addition to the determination of the snubber mode of j failure, in orNr to datermine if any safety-related component or system has been adversely affected by the inoperability of the snubber. The engineering evaluation shall determine whether or not the snubber mode of failure has imparted a significant effect or degradation on the supported component or system.

To provide assurance of snubber functional reliability, a representative sample of the installed snubbers will be functionally tested during plant shutdowns at refueling or 18 month intervals not to exceed two (2) years. Observed failures of these sample snubbers shall require functional testing of additional units.

Snubbers are classified and grouped by design and manufacturer but not by size. For example, mechanical snubbers utilizing the same design features of the 2-kip, 10-kip and 100-kip capacity manufactured by Company "A" are of the same type. The same design mechanical snubbers manufactured by Company "B" for the purposes of this Technical Specification would be of a different type, as would

. hydraulic snubbers from either manufacturer.

The service life of a snubber is evaluated via manuft.cturer input and information through consideration of the snubber service conditions and associated installaw .. and maintenance records (newly installed snubber, seal replaced, spring replaced, in high radiation area, in high temperature area, etc... ). The requirement to monitor the snubber service life is included to ensure that the snubbers periodically undergo a performance evaluation in view of their age l and operating conditions. These records will provide statistical bases for future consideration of snubber servica life. The

%gro requirements for the maintenance of records and the snubber service p f life review are not intended to affect plant operation.

F7 SYSTEM h =

The OPERABILITY of the SWE ensures

  • that sufficient co I capacity is available to bring the r nctor to a cold shutdown jl condition in the event that a barge explosion at the station's intake structure or any other extremely remote event would render all of the hw3) normal Service Water Systaajsupply pumpp inoperable.

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BEAVER VALLEY - UNIT 3/4 7 Amendmen M i edu

AttachmInt A-2 Beaver Valley Power Station, Unit No. 2 j Licence Amendment Reauest No. 139

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INSERT "B" The scenario of a postulated gasoline barge impact with the intake structure and coincident explosion disabling the SWS is a low probability event and is . outside those typically postulated by the NRC for reactor sites. Nonetheless, the SWE provides defense in-depth in assuring shutdown cooling capability. The requirement to operate the SWE is not coincident with a postulated Des 5gn Basis Accident, but only for the postulated gasoline barge impact event.

Although the SWE is a non-safety system which is not required to meet single active failure criteria, the system is designed with redundant pumps'and valves on a header to accommodate a single active failure on start-up. This design criteria provides a defense in-depth ,

in order to ensure the system can adequately mitigate the l consequences of the postulated event. An SWE pump can be manually 1 started on~the emergency bus during loss of offsite power after-the diesel loading sequence is complete. With no loss of power signal present, the SWE is automatically started upon receipt of low service water header pressure signal. This feature is provided to prevent inadvertent plant trip on loss of running service water pump and is not required for the design basis event. If there is a delay in starting the SWE, the auxiliary feedwater system is available to remove reactor core decay heat for a short tarm period.

The requirements for subsystem OPERABILITY are similar to those . of the SWS except that one subsystem is required to be OPERABLE in the MODES noted. The Limiting Condition for Operation reflects the low risk of the postulated event compared to more stringent requirements associated with safety related systems. The ACTION statement takes into account the low probability of both trains of SWS being disabled as a result of the postulated scenario coincident with one of the SWE j subsystems being OPERABLE. '

BEAVER VALLEY - UNIT 2 (Proposed Wording)

ATTACHMENT B Beaver Valley Power Station, Unit Nos. 1 and 2 )

License Amendment Request No. 264 and 139 4 REVISION OF BASES FOR SPECIFICATION 3/4.7.13 A. DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would revise the Bases section for Specification 3/4.7.13 pertaining to the Auxiliary River Water .

System (ARWS) for the Beaver Valley Power Station (BVPS) Unit I No. 1 and the Standby Service Water System (SWE) for BVPS Unit J No. 2. The Bases section would be modified by the addition of wording which discusses in greater depth the design bases of the system. The additional wording also provides a discussion on the basis for the requirements of the Limiting condition for Operation (LCO) and required actions should the LCO not be met.

Page format would be revised to permit incorporation of additional text and updating to current page fermat. The format changes include the addition of a new Bases page. The BVPS Unit No. 2 Index page XII would be revised to reflect the shifting of text due to page reformatting.

B. DESIGN BASES In response to the design basis event consisting of an explosion in conjunction with a gasoline barge impact, an alternate system is required to provide heat sink requirements when the Seismic  ;

I Category I intake structure is disabled by the postulated event.

In accordance with Regulatory Guide 1.27 - Ultimate Heat Sink, an alternate system should, as a minimum, be capable of providing its design function during site-related historic events.

Therefore, the alternate, designated as the ARWS/SWE, is designed I to include, but not limited to, the following criteria:

1. Historic earthquake 0.03g (surface motion).
2. Redundant - pumps and motor-operated valves are provided to accommodate a single active failure.
3. F1.ood protected to El. 705 ft (Standard Project Flood).
4. Low river level capability to El. 654 ft.
5. No tornado protection.
6. Located to preclude damage from gasoline barge impact /

explosion which may disable the Seismic Category I intake structure.

7. A Design Basis Accident (DBA) is not considered coincident with requirements for ARWS/SWE.

The ARWS/SWE is designed to accommodate unit shutdown from 100%

reactor power and subsequent cooldown of the reactor coolant

E ATTACHMENT B, continusd Licznte Amendment Request Nos. 264 and 139 Page 2-system to lesi than 200 F, after the postulated loss of the intake structure.

The ARWS/SWE is designed to duplicate the cooling capacity of the River / Service-Water System.

C. JUSTIFICATION The proposed changes reflect information previously ' addressed during the BVPS Unit No. 1 operating licensing activities and the BVPS Unit No. 2 Preliminary Safety Analysis Report (PSAR) question-response activities that resulted in Technical Specification 3/4.7.13. The ac$itionC information is being delineated in the Bases section for Spetification 3/4.7.13 to aote why this_ Technical Specification is net required to follow the more restrictive requirements associated Nith safety related systems used ' to mitigata design basis accidents (DBAs). The additional wording also provides a discussion on the requirements of the LCO and required actions should the LCO not be met. This additional wording provides the user with a better insight on the bases _of these requirements.

D. SAFETY ANALYSIS The proposed change only clarifies the Bases for Specification 3/4.7.13.- The minimum required equipment for continued plant operation remains unchanged. The performance criteria for determining equipment operability remains unchanged. There are i no DBAs where the ARWS and SSWS are credited. There will be no '

adverse effect or challenges imposed on safety related systems as a result of this proposed change. Therefore, the proposed change has no adverse impact on~any safety analysis result.

E. NO SIGNIFICANT HAZARDS EVALUATION The no significant hazard considerations involved with the

. proposed. amendment have been evaluated. The evaluation focusing on the three standards set forth in 10 CFR 50.92(c) are as quoted below:

The Commission may make a final determination, pursuant to i 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 accident from any accident previously evaluated; or B-2

ATTACHMENT B, continusd License Amendment Request Nos. 264 and 139 Page 3 (3) Involve a significant reduction in a margin of safety.

The following evaluation is provided for the no significant hazards consideration standards.

1. Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed changes to the Bases for Specification 3/4.7.13 provide clarifications of the design and licensing bases for the Auxiliary River Water System (ARWS) for Beaver Valley Power Station (BVPS) Unit No. 1 and the Standby Service Water System (SWE) for BVPS Unit No. 2. There are no Design Basis Accidents (DBAs) where the ARWS and SWE are credited.

Therefore, since the proposed change only involves the ARWS and SWE, there can be no increase in the probability of occurrence of a DBA previously evaluated in the Updated Final Safety Analysis Report (UFSMt) .

The performance of the subject equipment associated with the ARWS and SWE will not be affected since the proposed change only provides additional clarification. Thus the proposed change will not significantly increase the consequences of accident previously evaluated.

The remaining changes which include a revision to the Index page and page format are editorial in nature and do not affect plant safety.

2. Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?

There are no hardware changes associated with this request for license amendment nor are there any changes in the method by which any safety related plant system performs its safety function. Plant operation will not be changed.

No new accident scenarios, transient precursors, failure mechanisms, or limiting single failures are introduced as a result of this proposed amendment. There will be no adverse effect or challenges imposed on safety related systems as a result of _ this proposed change. Therefore, the proposed

. change does not create the possibility of a new or different

! kind of accident from any previously evaluated.

3. -Does the change involve a significant reduction in a margin of safety?

The proposed change only clarifies the Bases for Specification 3/4.7.13. The proposed changes do not affect the Lcceptance criteria for any analyzed event nor is there a B-3 1

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ATTACHMENT B, continu d License Amendment Request Nos. 264 and 139 Page 4 1 change to any Safety Analysis Limit (SAL). Maintaining the SAL preserves the margin of safety.

There will be no effect on the manner in which safety limits or limiting safety system settings are determined nor will there be any effect on those plant systems necessary to assure the accomplishment of protection functions.

Therefore, the proposed changes do 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 satisfy the requirements of 10 CFR 50.92 (c) and, accordingly, a no significant hazards consideration finding is justified.

G. ENVIRONMENTAL CONSIDERATION This license amendment request provides a clarification, in the form of revision to the Bases Section, of a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.

It has been determined that this license amendment request involves 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. This license amendment request does not change requirements with respect to installation or use of a facility component located within the restricted area or change an inspection or surveillance requirement. The category of this licensing action does not individually or cumulatively have a significant effect I on the human environment. Accordingly, this license amendment '

request meets 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 issuance of this license amendment request. i H. UFSAR CHANGES No additional UFSAR changes, beyond those in the process of being incorporated, have been determined to be necessary as a result of this proposed amendment.

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