ML20207F086
| ML20207F086 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/09/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20207F035 | List: |
| References | |
| GL-87-09, GL-87-9, NUDOCS 8808180211 | |
| Download: ML20207F086 (5) | |
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pMt%q'o UNITED STATES g
NUCLEAR REGULATORY COMMISSION o
E WASHINGTON, D. C. 20666
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N05. 129 AND 4 TO FACILITY OPERATING LICENSE N05. DPR-66 AND NPF-73 DUQUESNE LIGHT COMPANY OHIO EDIS0N COMPANY PENNSYLVANIA POWER COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412
1.0 INTRODUCTION
Duquesne Light Company)(the licensee, acting By letter dated January 25, 1988, as agent for itself and the other utilities listed above requested amendments to Facility Operating License Nos. DPR-66 and NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 and 2.
The proposed amendments would revise Sections 3.0 and 4.0 of the Technical Specifications (TS) to incorporate the changes recomended in NRC's Generic letter (GL) 87-09.
In this letter, the NRC has concluded that certain recomended modifications to TSs 3.0.4, 4.0.3 1
and 4.0.4 would clarify the intent of these TSs and would resolve three problems associated with the existing requirements, as follows:
(1) the revision of TS 3.0.4 would remove unnecessary restrictions on operational mode changes in these cases where conformance with action statement requirements provides an acceptable level of safety for continued operation for an i
unlimited period of time; (2) the revision of TS 4.0.3 would provide a 24-hour i
delay before impicw nting TS action statement requirements due to a missed surveillance in those cases where the required restoration time 11 loss than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; and (3) the revision of TS 4.0.4 would assure that surveillance i
requirements do not prevent the plant's passage through or to operational modes as required to comply with TS action statement requirements.
2.0 EVALUATION Technical Specification 3.0.4 The existing TS 3.0.4 specifies, in part, that "Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the conditions of the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statement requirements." The staff position in GL 87-09 is that this TS, as currently written to exclude reliance on provisions contained in the 8808180211 880809 DR ADOCK O 34
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2-ACT!0N requirements, "unduly restricts fdcility operation when conformance to the ACTION requirements provides an acceptable level of safety for continued operation.
For en LC0 that has ACTION requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with those ACTION requirements.
This is consistent with NRC's regulatory requirements for an LCO.
The restriction on a change in operational modes or other specified conditions should apply only where the ACTION requirements establish a specified tin,e interval in which the LCO must be met ur a shutdown of the facility would be reouired. However, nothing in this staff position should be interpreted as endorsing or encouraging a plant startup with inoperdble equipment. The stdff believes that good practice should dictate that the plant startup should normally be initiated only when all required equipinent is operable and that startup with inoperable equipment must be the exception rather than the rule."
In accordance with this position, the staff recomended in GL 87-09 the following change to replace the first sentence of TS 3.0.4.:
"Entry into an OPERATIONAL MODE or other specified ccndition shall r.ot be made when the cotiditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL MODE or specified condition may be made in accordance with ACTION requirements when confurmance to them permits continued operation of the facility for an unlimited period of time."
The licensee's proposed change to TS 3.0.4 conforms to the above staff recommendation and is, therefore, acceptable.
The revised TS 3.0.4 eliminated the need for exceptions to it (i.e. stating that TS 3.0.4 does not opply) for a number of individual systems. 'For such systems, the exceptions to TS 3.0.4 are thus deleted.
Since these deletions are consistent with the revised form of TS 3.0.4, we find that they are also acceptable.
Technical Specification 4.0.3 Beaver Valley TS 4.0.3 currently states that failure to perform a surveillance requireinent within the specified surveillance interval shall constitute a failure to meet the operability requirements for en LCO. Thus, the TS requires the innediate implementation of the shutdown actions of TS 3.0.2.
In GL 87-09, the staff finds:
"It is overly conservative to assume that systems or components are inoperable when a surveillance requirenent has not been performed.
The opposite is in fact the cose; the vast majority of surveillances demonstrete that systems or components in fact are operable.
When a surveillance is missed, it is primarily a question of operability that has not been verified by he performance of the required surveillance.
4 Becausa: the ellowable outage time limits of some ACTION requirements do nut provide an appropriate time limit for performing a missed surveillance before shutdown requirements may apply, the Technical Specifications should include a time limit that would allow e celay of the required dctions to permit the performance of the missed surveillance.
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! l This time limit should be based on considerations of plant conditions, adequate planning, availability of personnel, the time required to perfonn the surveillance, as well as the safety significsnce of the delay in completion of the surveillance. After reviewing possible limits, the staff has concluded that, based on these considerations, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the ACTION requirements are less than this time limit or when shutdown ACTION requirements apply. The 24-hour time limit would balance the risks associated with an allowance.for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems wnen the alternative is a shutdown to comply with ACTION requirements before the surveillance can be completed."
On the basis of these considerations, the staff recomended in GL 87-09 the following revised version of TS 4.0.3:
"Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation. The time limits of the ACTION requirements are applicable at the time it is identified that a Surveillance Requiremant has not been performed. The ACTION requirements may be delayed for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit tne completion of the surveillance when the allowable outage. time limits of the ACTION requirements are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
In GL 87-09, the staff also recomended the deletion of statements that refer to TS 4.0.3 in individual specifications.
These statements are deleted because the revised TS 4.0.3 is always applicable and there are no exceptions for individual specifications.
The licensee's proposed change to TS 4.0.3 is identical to the above version and is, therefore, acceptable.
Technical Specification 4.0.4 Beaver Valley TS 4.0.4 currently requires that before a new Operational Mode is entered, Surveillance Requirements pertaining to the new mode are to be performed within time limits specified by TS 4.0.3.
A conflict arises when ACTION requirements require a mode change, but the surveillance requirements which become applicable in the new modo have not been performed within the specified interval so that TS 4.0.4 does r.at permit a mode change.
If an exceptior, to TS 4.0.4 is allowed (e.g. for cases where the surveillance requirements can only be completed after entry into the mode to which they apply), there may still be a ccaflict with TS 4.0.3 if the surveillance requirements have not been performed within the allowed surveillance interval.
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. In GL 87-09, the staff took the following position:
"the potential for a plant upset and challenge to safety systems is
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heightened if surveillances are perforrned during a shutdown to comply with Action Requirements.
It is not the intent of Specification 4.0.4 to prevent passage through or to operational modes to comply with Action Requirernents and it should not apply when mode changes are innposed by i
Action Requireinents. Accordingly, Specification 4.0.4 should be modified to note that its provisions shall not prevsnt passage through or to operational modes as required to comply with Action Reouirements. A similar provision is included in Specification 3.0.4 It is not the intent of Specification 4.0.3 that che Action Requirements should preclude the perforinance of surveillance when an exception to Specification 4.0.4.is allcwed.
However, since Specification 4.0.3 has been changed to permit a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in the applicability of the Action Requirements, an appropriatc time limit now exists for the completion of those Surveillance Requirements that become applicable when an ex aption to Specification 4.0.4 is allowed."
Based on these considerations, the staff recorrerended in GL 87-09 that the following sentence be added to TS 4.0.4.:
"This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION Requirements."
The licensee's proposed change to TS 4.0.4 1s identical to the NRC stiff's recoininendation and is, therefore, acceptable.
3.0 ENVIRONMENTALCONSIDERATIg These amenoments involve changes in the installation or use of facility com-ponents located within the restricted area as defined in 10 CFR Part 20 and changes in surveillance requirements.
The staff has determined that the amendments involve no sigrifiCont 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 3
exposure. The NRC staff has made a determination that the amendinents involve no significant hazards consideration, and there has been no public comment on
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such finding. Accordingly, the amendments meet the eli categorical exclusion set forth in 10 CFR 51.22(c)(9). gibility criteria for Pursuant to 10 CFR 51.22(b) no environmental impact staterr. ant or enviraranental assessment need be prepared in connection with the issuance of these amendments.
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4.0 CONCLUSION
We have concluded, based on the consideratiosis discussed above, that:
(1) there is reasonable assurance that the health dnd safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of these amendrents will not be inimical to the common defense and security or to the health and safety of the public.
Dated: August 9,1988 Principal Centributor:
Peter S. Tam t
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