ML20215D236
| ML20215D236 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/30/1986 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8610140047 | |
| Download: ML20215D236 (34) | |
Text
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T.i.cno.<44232 3-ec:0 Nuct.ar Group P.O. Box 4 sn comanort. PA 150U4004 July 30, 1986 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Attn:
Dr. Thomas E. Murley, Regional Administrator Region 1 631 Park Avenue King of Prussia, PA 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 1985 Report of Facility Changes, Tests and Experiments Gentlemen:
This letter forwards.the 1985 annual Report of Facility Changes, Tests and Experiments, in accordance with 10CFR50.59.
The report covers the period January 22, 1985 to January 22, 1986 to coincide with the annual FSAR update.
A brief description of each facility
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evaluation for each change.
and procedure change is provided along with a summary of the safety Very truly yours,
(~
lJos J/ J. Ca y
'ce Prcsident, Nuclear cc: Mr. W.
M. Troskoski, Resident Inspector U.
S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission j
c/o Document Management Branch Washington, DC 20555 l
Director of Nuclear Reactor Regulation (39)
U. S. Nuclear Regulatory Commission Attn:
Mr. R. C. DeYoung, Director Office of Inspection and Enforcement Washington, DC 20555 QDQ 8610140047 860730~^
l' DR ADOCK 0D000334 g(
s TABLE OF CONTENTS 3
DESIGN CHANGES PAGE DCP 129 Permanent Steam Generator Blowdown 1
Demineralizers DCP 174 Water Treatment System Modification 2
DCP 219 River and Raw Water Pump Seal and Bearing 3
Piping Replacement DCP 286 Modify Vibration Supports on Charging Pumps 4
1B and 1C DCP 333 Reactor Vessel Level Instrumentation System 5
(RVLIS)
DCP 471 Liquid Waste System Modifications 6
DCP 544 BVPS Common Facilities:
New Office Warehouse 8
DCP 641 Additional Emergency Lighting - Appendix R 10 DCP 665 Retube Reactor Plant Component Cooling Water 12 Heat Exchangers (CC-E-1A/lE) with Ferritic Stainless Steel Tubes
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DCP 684 Communications - Alternate Safe Shutdown 14 DCP 689 Appendix R Modification of Diesel Generator 16 Bldg. CO2 Circuit DCP 695 Lag Compensation for RCS AT and Tavg Summators 17 DCP 702 CR-27 Load Cell System Replacement 19 PROCEDURE CRANGES Operating Manual Alternate Safe Shutdown From 20 Chapter 56C Outside Control Room Operating Manual Fire Prevention and Control 26 Chapter 56B Procedures Operating Manual
.Off-Normal Blender Boration or 27 Chapter 7.4 Dilution for Shutdown operation Operating Manual Upgraded Emergency Operating 27 Chapters 53A and 53B Procedures Corrective Maint-Tube Leak Check of Reactor Plant 29 enance Procedure CCR Heat Exchangers, Field Rev-CMP l-15CC-E-1A-B-C-1M, ision 85-M-06 Revision 4
TABLE OF CONTENTS, (Continued) i PROCEDURE CHANGES, (Continued)
Maintenance Surveillance Reactor Trip Breaker RTA 29 Procedures 1.17, 1.18, (RTB, BYB, and BYA) Undervoltage 1.19, and 1.20, Revi-Trip Force Test sion 0 Maintenance Surveillaice Power Range Calibrations 30 Procedure 2.03(4)(5)(5);
Revision 27, (26)(26)(25)
Corrective Maintenance Train A(B) Reactor Trip Breaker 30 Procedure 1-6RP-BK-UVTA-UV Coil Time Response Test II (2I); Revision 0, (0)
Specific Nuclide Activity Deter-31 mination (Reactor Coolant System)
Secondary Water specification 31 Diesel Fuel Oil Specification 31 i
DUQUESNE LIGHT COMPANY Page 1 Beaver Valley Power Station Docket'No. 50-334. License No. OpR-66 OESIGN CHANGE NO. 129 PERMANENT STEAM GENERATOR BLOWOOWN DEMINERALIZERS This design change will install a new, higher-capacity, blowdown system.
It will be tied-in with the present blowdown system. The new portion of the system will be used for normal operations and the old portion will be used for isolation of blowdown flow from a steam generator that experiences a detected primary-to-secondary side RCS leak. This modification will increase the steam generator blowdown flow capacity and will provide for better control over the secondary side water chemistry.
CONCLUSION - SAFETY EVALUATION This design change is safe and does not constitute an unreviewed safety question.
The Technical Specifications will not require any changes, however, the UFSAR must be revised to include the additional equipment. The safety evaluation was reviewed and accepted at OSC meeting BV-OSC-87-84.
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BASIS FOR SAFETY EVALUATION 1.
Is the probability of occurrence or the consequence of an accident or malfunction of equipment important to safety as previously evaluated in the Updated Final Safety Analysis Report (UFSAR) increased?
NO, Reason: The proposed design modification would only increase the flow capacity of the existing non-safety related portion of the Steam i
Generator Blowdown System.
2.
Is the possibility for an accident or malfunction of a different ty;:c than any previously evaluated in the Updated Final Safety Analysis Report N00 (UFSAR) created?
Reason: The proposed modification would not affect any safety related systems or components.
3.
Is the margin of safety as defined in the basis for any Technical NO Specification reduced?
l Reason: The rate of RCS leakage from the primary to the secondary side as limited by the Technical Specifications is not affected by this design change.
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DUQUESNE LIGHT COMPANY Page 2 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 174 VATER TREATMENT SYSTEM MODIFICATION The purpose of this design change is to increase the reliability and capacity of the demineralized water system; to supply demineralized water to Unit 2, VT-TK-10 and VT-TK-ll; and supply. demineralized water from VT-TK-26 to users previously supplied from the surge line between VT-TK-11 and CN-SC-IA.
CONCLUSION - SAFETY EVALUATION This modification vill not increase the probability of an occurrence or the consequence of an accident or malfunction of equipment important to safety as a new type of accident than any previously previously evaluated, or create evaluated in the UFSAR.
This modification vill, also, not adversely affect the margin of safety as defined in the basis for any Technical Specification Section and an unreviewed safety question is not involved.
This modification does require a change to the UFSAR.
The safety evaluation was reviewed and accepted at OSC meeting BV-0SC-26-84 BASIS FOR SAFETY EVALUATION Is the probability of an occurrence or the consequence of an accident or 1.
malfunction of equipment important to safety as previously evaluated in NO.
the Updated Final Safety Analysis Report (FSAR) increased?
The proposed modification vill not adversely affect any of the Reason:
plant safety related components--or equipment nor increasa the probability or likelihood of any accident or malfunction of associated equipment as described or evaluated in Section 14 Safety Analysis of the UFSAR.
2.
Is the possibility for an accident or malfunction of a different type than any previously evaluated in the Final Safety analysis Report NO.
created?
Ressor-The proposed modification vil'1 not adversely affect the operation of any safety related -equipment as described in Sections 9.11 or 10.3.5 of the UFSAR.
3.
Is the margin of safety as defined in the basis for any Technical NO.
Specification reduced?
adversely affect the margin of Reason:
This modification vill not--basis for Section 3/4.7.1.3 or any safety as described in the other section of the Technical Specifications.
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DUQUESNE LIGHT COMPANY'
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Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 219 RIVER AND RAV VATER PUMP SEAL AND BEARING PIPING REPLACEMENT The purpose of this modification is to replace the 1" and smaller carbon steel seal and bearing cooling water piping and valves to the River Vater Pumps (VR-P-1A, IB, and IC) and Rav Vater Pumps (VR-P-6A and 6B) with stainless steel tubing and valves. Internal corrosion of the small diameter carbon steel pipe is causing a reduction in flow to the pump seals and bearings, warranting the change to stainless steel piping and valves.
Also, a valve and a cleanout vill be added to the 2" supply header.
CONCLUSION - SAFETY EVALUATION This change is considered safe and does not involve a change to the Technical Specifications. A change to the Updated FSAR will be required. The safety evaluation was reviewed and accepted at OSC meeting BV-OSC-101-83 BASIS FOR SAFETY EVALUATION 1.
Is the probability of occurrence or the consequence of an accident or malfunction of equipment important to safety as previously evaluated in the Updated Final Safety Analysis Report (UFSAR) increased?
NO.
Reason:
Replacement of the carbon steel piping and valves with stainless steel vill mitigate the effects of corrosion and increase the integrity of the River Vater system as described in the UFSAR, Section 9.9.
2.
Is the possibility for an accident or malfunction of a different type than any previously evaluated in the Updated Final Safety Analysis NO.
Report (UFSAR) created?
Reason:
This modification vill not alter the safety function of the River Vater System as described in the UFSAR. Also, there are no high energy lines located in the intake structure, minimizing the effects of line breaks.
3.
Is the margin of safety as defined in the basis for any Technical NO.
Specification reduced?
Reason:
This modification vill not reduce the margin of safety as defined in the basis for the Technical Specifications 3/4.7.4.
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DUQUESNE LIGHT COMPANY age 4 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 286 MODIFY VIBRATION SUP0RTS ON CHARGING PUMPS 1B & IC The purpose of this design change was to install rib plate supports on the drip pockets of the charging pumps.
The objective was to reduce vibration of the drip pocket between the pump case and bearing housing at the discharge end of the pump.
CONCLUSION - SAFETY EVALUTION This change is considered safe and does not involve an unreviewed safety question or require a change to the Technical Specifications.
1 The safety evaluation was reviewed and accepted at OSC Meeting BV-OSC-147-80 BASIS FOR SAFETY EVALUATION an occurrence of an accident or malfunction of 1.
Is the probability of equipment important to safety as previously evaluated in the FSAR NO.
increased?
Reason:
This change vill make the pumps more reliable.
2.
Is the possibility created for an accident or malfunction of a different NO.
type than any previously evaluated in the FSAR?
Reason:
Pump failure is the only possibility and has been previously
(
evaluated.
3.
Is the margin of safety reduced as defined in the basis for any NO.
technical specification?
Reason:
This change vould help increase the margin of safety for these pumps.
DUQUESNE LIGHT COMPANY Prgt 5 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 333 REACTOR VESSEL LEVEL INSTRUMENTATION SYSTEM (RVLIS)
The objective of this modification is to provide additional instrumentation for the detection of inadequate core cooling.
The modification requires connections to the Reactor Vessel Head, Reactor Coolant Hot Leg Piping, and In-Core Instrumentation Conduits.
Instrumentation tubing and cabling penetrate the containment to level transmitters located outside the containment. The instrument signals vill be wired from the transmitters and temperature sensor to microprocessors in the control room. Alarm signals from the microprocessors vill be sent to the annunciators on the main control board.
CONCLUSION - SAFETY EVALUATION Thir modification is considered to be safe in that the change vill not create the possibility of a new accident, increase the possibility of previously analyzed accidents, or reduce the margin of safety defined in the Technical Specifications.
The safety evaluation was reviewed and accepted at OSC Meeting BV-0SC-87-84 BASIS FOR SAFETY EVALUATION 1.
Is the probability of occurrence or the consequence of an accident or malfunction of equipment important to safety as previously evaluated in the Updated Final Safety Analysis Report (UFSAR) increased?
NO.
Reason:
There is no change to the accident or transient analysis as
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described in Section 14.3 resulting from the implementation of RVLIS.
2.
Is the possibility for an accident or malfunction of a different type than any previously evaluated in the Updated Final Safety Analysis NO.
Report (UFSAR) created?
Reason:
The connection of the RVLIS to the reactor coolant pressure boundary satisfies the closed system isolation criteria.
Reactor coolant is present in the tubing up to the high volume sensors. The tubing from the high volume sensors, through the containment penetration to the hydraulic isolators does not contain reactor coolant.
The hydraulic isolators and high volume sensors serve as an isolation device in the event of failure of the tubing.
3.
Is the margin of safety as defined in the basis for any Technical NO.
Specification reduced?
Reason:
The RVLIS is not presently addressed in the Technical Specification, although a change vill be required as indicated on NUREG 0737 Section II.F.2.
The RVLIS may enhance the margin of safety by supplementing the Core Subcooling Monitor.
DUQUESNE LIGHT COMPANY Pcga 6 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 471 LIQUID VASTE SYSTEM H0DIFICATIONS permanent Liquid Vaste The purpose of this modification is to provide a
Demineralizer System to replace the temporary Liquid Vaste Cleanup Demineralizer System presently in u ".
This design change provides a
,- a backup to the Liquid Vaste filter / ion exchanger cleanup train which
-en Evaporator (LV-EV-1).
The Liquid
".1 ineralizer System vill be permanently housed in a shielded cubicle
.n the Decontamination Building.
A piping tie-in to the Boron Recovery Syste ill facilitate transfer from the ar 7B.
New piping vill be installed test tanks to the Liquid Vaste Tanks 7A to provide additional vent capacity for SU-TK-8 that includes a new HEPA filter and vents to the Solid Vaste Building's atmosphere.
CONCLUSION - SAFETY EVALUATION This modification is considered to be safe in that the change vill not create a new accident, increase the possibility of previously the possibility of analyzed accidents, or reduce the margin of safety defined in the Technical Specifications.
The safety evaluation was reviewed and accepted at OSC Meeting BV-0SC-15-85.
BASIS FOR SAFETY EVALUATION or the consequence of an accident or 1.
Is the probability of occurrence malfunction of equipment important to safety as previously evaluated in the Updated Final Safety Analysis Report (UFSAR) increased?
NO.
Reason:
The accident of concern in this case is two-fold.
First, is the " Accidental Release of Vaste Liquid" discussed in UFSAR 15.2.2.
Section 14.2.2.3,
" Conclusions",
indicates that protection from this accident is by administrative controls, batch handling, and containing the system within the station.
All of these controls vill be in effect in the new system.
Section 14.2.2.2, " Analysis of Effects and Consequences" does not address the Decontamination Building.
Since liquid processing components vill also be located in the Decontamination Building, thic fact should be included in the lead-in statement to this section.
However, UFSAR Section 9.15, " Decontamination Facility", states that in the event of leakage from piping or equipment, all areas of the building are provided with drain connections which are routed to the sump.
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DUQUESNE LIGHT COMPANY p,g, 7 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 The second area of concern is the potential for " Missiles and Pipe Rupture" discussed in UFSAR 5.2.6.
This type of accident is addressed due to the provision for a rack of nitrogen
'K' bottles and associated piping.
The
'K' bottles contain high pressure gas, and therefore represent potential missiles should a rupture take place.
However, the nitrogen bottle rack vill not be located near any BVPS Unit 1 safety-related equipment and is outside of any structures housing such equipment.
Therefore, this modification vill not increase the possibility of safety-related equipment damage due to missile hazards.
design pressure of 350 The nitrogen backflush piping with a psig is considered high-energy under the criteria of Appendix D to the UFSAR.
However, no equipment required for safe shutdown is located in the Decontamination Building.
Therefore, no analysis for the consequences of a pipe break is requir,ed.
2.
Is the possibility for an accident or malfunction of a different type than any previously evaluated in the Updated Final Safety Analysis NO.
Report (UFSAR) created?
Reason:
The Liquid Vaste Demineralizer Cubicle shield vall and curb is is any piping whose failure designed for seismic loading, as could result in damage to safety-related equipment. Drain lines from the sample sink and the shielded cubicle to the Decon Building Sump are provided. This is consistent with the previous Liquid Vaste System design and creates no new type of accident.
The UFSAR contains analyses of the potential hazards of missiles and pipe ruptures which could damage safety-related equipment. As discussed in the response to Question 1, the intended modification does not present any new concerns from these standpoints.
3.
Is the margin of safety as defined in the basis for any Technical NO.
Specification reduced?
Reason:
Monitoring of liquid vaste vill be performed prior to discharging to ensure that effluent activity is within the margin of safety as defined in the basis of Section 3/4.11.1.
" Liquid Effluents".
DUQUESNE LIGHT COMPANY
- E' Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 544 BVPS COMMON FACILITIES: NEV 0FFICE WAREHOUSE This design change involves the design and construction of a new 105,000 square foot varehouse located on the Morrow property adjacent to state road LR 483 and Ferry Hill Road.
This warehouse vill provide material receiving and handling for DCP materials, small and large parts, and clean storage material for both BVPS No. 1 and 2 sites.
The only tie-ins to existing plant components is for the building utilities.
Fire Protection vill be supplied by a 12" line tied-in to the existing 12" line serving the E.R.F.,
training and simulator buildings. Domestic water vill be supplied from the existing 2" vater line and sanitary vill be tied-in to the existing 6" line that services the above mentioned buildings. Adequate capacity exists in each of these systems to include service to the varehouse.
CONCLUSION - SAFETY EVALUATION Implementation of this design change is considered to be safe. A change to UFSAR Section 9.10 and Figure 9.10-1 is required to include the Fire Protection System tie-in for the new offsite varehouse. Also, the new offsite varehouse should be added to UFSAR Table 1.7-1, Nonessential Common Structures. No change to the Technical Specifications is required.
The safety evaluation was reviewed and accepted at OSC Meeting BV-0SC-22-84 BASIS FOR SAFETY EVALUATION 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 Updated Final Safety Analysis Report (FSAR) increased?
NO.
Reason:
The addition of the new offsite varehouse in regards to the Fire Protection System tie-in vill not increase the probability or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in UFSAR Section 14 since this addition vill not adversely affect any safety-related equipment protected by tHe Fire Protection System as described in UFSAR Section 9.10.
2.
Is the possibility for an accident or malfunction of a different type than any previously evaluated in the Updated Final Safety Analysis NO.
Report created?
Reason:
The addition of the new offsite varehouse in regards to the Fire Protection System tie-in vill not adversely affect the Fire Protection System as described--in UFSAR Section 9.10 since adequate capacity exists in the existing system to supply the new offsite varehouse.
DUQUESNE LIGHT COMPANY p,g, 9 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 3.
Is the margin of safety as defined in the basis for any Technical NO.
Specification reduced?
Reason:
The margin of safety as defined in the basis for Technical Specifications 3/4.3.3.6 - Fire Detection Instrumentation and 3/4.7.14 - Fire Suppression System vill not be reduced because the existing Fire Protection System is of adequate capacity to support the new offsite varehouse Fire Protection System, therefore the operability of the present fire protection system vill not be compromised.
DUQUESNE LIGHT COMPANY Pega 10 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 641 ADDITIONAL EMERGENCY LIGHTING - APPENDIX R The purpose of this design change is to provide emergency lighting to comply with 10CFR 50 Appendix R Section III.J vhich states " Emergency lighting units with at least an 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto."
The lighting units to be installed under this design change vill supplement the Appendix R lighting previously installed by DCP 268 and vill include the following new safe shutdown equipment and access routes thereto:
DCP 562 - Dedicated Aux. Feed Pump Control Panel (s) and the Feedvater Bypass Regulating Valves.
DCP 563 - Backup Indicating Panel and Associated Transfer Svitches.
DCP 626 - Local Steam Header Pressure Gages.
All the Appendix R emergency lighting, including the previously installed lighting, vill be tested to meet the latest NRC guidance.
CONCLUSION - SAFETY EVALUATION Implementation of this design change is considered to be safe. No change to the Technical Specifications is required.
An addition to Updated FSAR
' Appendix D, Figures D.1-1 thru D.lL12 is recommended.
The safety evaluation was reviewed and accepted at OSC Meeting BV-0SC 47-84.
BASIS FOR SAFETY EVALUATION 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 Updated Final Safety Analysis Report (FSAR) increased?
NO.
Reason:
The additional emergency lighting to be installed vill not increase the probability of an occurrence or the consequences of an accident or malfunction of equipment important to safety as previously evaluated in UFSAR Section 14.
The emergency lighting is being provided for areas which contain equipment needed for a safe shutdown.
DUQUESNE LIGHT COMPANT Page 11
-Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 2.
Is the possibility for an accident or malfunction of a different type than previously evaluated in the Updated Final Safety Analysis Report NO.
created?
Reason:
The addition of the emergency lighting vill not adversely affect the operation of the Fire Protection System as described in UFSAR Section 9.10.
Since the emergency lighting vill supplement the lighting already installed, it is concluded that an accident or malfunction of a different type than previously evaluated in the UFSAR is not created.
3.
Is the margin of safety as defined in the basis for any Technical NO.
Specification reduced?
Reason:
The margin of safety as defined in the basis for any Technical Specification vill not be reduced since there are no Technical Specification associated with Emergency Lighting.
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DUQUESNE LICHT COMPANY Page 12 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 665 RETUBE REACTOR PLANT COMPONENT COOLING VATER HEAT EXCHANGERS (CC-E-1A/1C) VITH FERRITIC STAINLESS STEEL TUBES The purpose of this modification is to replace the 304L Stainless Steel, 18 BVG, tubes in the Reactor Plant Component Cooling Vater Heat Exchangers, CC-E-1A and CC-E-1C, with tubes made of 20 BVG, Sea-Cure, a ferritic stainless steel alloy. The material change to Sea-Cure vill provide better resistance to crevice corrosion, and should, in fact, eliminate this type of corrosion due to manganese dioxide deposits.
Also, by reducing the vall thickness of the tubes, the heat transfer capabilities should be improved.
CONCLUSION - SAFETY EVALUATION This design change is considered to be safe and does not effect the bases of the technical specifications.
Additionally, the new tube material and vall thickness shall provide services which are as good as or better than the existing tubes. By making these modifications an unreviewed safety question does not exist.
The safety evaluation was reviewed and accepted at OSC Meeting BV-0SC-77-84.
BASIS FOR SAFTY EVALUATION 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 Updated Final Safety Analysis Report (FSAR) increased?
NO.
Reason:
By replacing the existing tubes with Sea-Cure, which has a slightly lover density, and maintaining this modification as a seismic Category I design, the probability of an occurrence or the consequence of an accident or malfunction of equipment important to safety as previously evaluated in the UFSAR, Section 9.4.3.1 vill not be increased.
2.
Is the possibility for an accident or malfunction of a different type than any previously evaluated in the Updated Final Safety Analysis NO.
Report created?
Reason:
The rupture of component cooling water heat exchange tubes or shell is considered unlikely, because of the system's lov operating pressure and temperature, as stated in Table 9.4-4 of the UFSAR. However, if such a rupture occurs to one of the heat exchangers, it can be isolated, with the remaining two heat exchangers performing 100 percent of the system capability. Moreover, in the event of a complete loss of component cooling water, a safe shutdown of the reactor c.in be achieved and the plant may be maintained in the hot standby condition indefinitely.
Therefore, the possibility of an accident or malfunction of a
different type than any previously evaluated in the UFSAR is not created.
DUQUESNE LIGHT COMPANY Page 13 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 3.
Is the margin of safety as defined in the basis for any Technical NO.
Specification reduced?
Reason:
The margin of safety as defined in the basis of Technical Specification 3/4.7.3 vill not be reduced as a result of this modification.
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DUQUESNE LIGHT COMPANY Page 14 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 684 COMMUNICATIONS - ALTERNATE SAFE SHUTDOVN In the event of a fire, which results in operators leaving the control room, the plant can be shut down using the back up indicating panel and manually operating equipment.
This modification vill enhance the existing station communication system and provide independent circuits to allow communication to operators manually operating equipment during an alternate safe shutdown procedure.
The dedicated / independent communication system vill be independent from fire areas which could affect operation from the control room ie:
control room, cable spreading room, process instrument room and communication equipment and relay room. This communication system vill use the ERF switchboard.
CONCLUSION - SAFETY EVALUATION The communication system enhances the performance of a safe shutdown from the BIP by allowing the operators to quickly communicate with operators manually operating equipment in the plant.
The safety evaluation was reviewed and accepted at OSC Meeting BV-0SC-30-85.
BASIS FOR SAFETY EVALUAITON l.
Is the probability' of an occurrence or the consequence of an accident or malfunction of equipment important to safety as previously evaluated in the Updated Final Safety Analysis Report (FSAR) increased?
NO.
Reason:
This modification allows the operators to perform an alternate safe shutdown from the BIP in the event of a normal communication system failure due to a fire or loss of offsite power. UFSAR Section 9.17.10 states that the design of BVPS-1 precludes the necessity of having work stations on the plant site where it may be necessary for plant personnel to communicate with the control room or the emergency shutdown panel during and/or following transients and/or accidents in order to mitigate the consequences of the event and to attain a safe cold plant shutdown.
The new dedicated / independent communication system vill not affect the operation of ainy system previously assumed to function in UFSAR Chapter 145 accident analyses.
2.
Is the possibility for an accident or malfunction of a different type than previously evaluated in the Updated Final Safety Analysis Report created?
NO.
Reason:
The use of any safety system is not impaired by the additional communication system.
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DUQUESNE LIGHT COMPANY Page 15 Beaver Valley Power Station Docket No. 50-334. License No. OPR-66 3.
Is the margin of safety as defined in the basis for any Technical Specification reduced?
NO Reason: The only tech. spec. on the communication system, 3.9.5, applies to refueling operations during core alternations.
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DUQUESNE LIGHT COMPANY Page 16 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 689 CIRCUIT APPENDIX R MODIFICATION OF DIESEL GENERATOR BLDG CO2 This minor design change vill relocate a relay contact in each of the DGl and DG2, CO,, control circuits to prevent a fire induced short circuit from causing a spurious operation of the respective diesel generator building CO, of the C0 system in the dieset operation suppression system.
Spurious disablingtheemerhencydieselgenerators.
generator building could result in The function of this relay contact is to prevent operation of the C0 system 9
if there is a concurrent CIB and loss of offsite power. This function vill not be affected by this modification.
CONCLUSION - SAFETY EVALUATION This design change is considered to be safe and does not present an unreviewed safety question. The modification vill not affect the permissive function which prevents operation of the CO,, system if there is a concurrent CIB and a loss of offsite power.
The modification vill not affect any of the diesel generator circuits or operation of the diesel generator during any accident.
The safety evaluation was reviewed and accepted at OSC Meeting BV-OSC 48-85.
BASIS FOR SAFETY EVALUATION 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 Updated Final Safety Analysis Report (FSAR) increased?
M.
Reason:
The function and operation of the C0,3 fire suppression system vill remain.the same except for the alarm and annunciator under certain conditions.
However these conditions require establishment of a fire vacch.
The operation of the diesel generators during any accident vill not be affected by the modification.
2.
Is the possibility for an accident or malfunction of a different type than previously evaluated in the Updated Final Safety Analysis Report NO.
created?
Reason:
The modification of the C0 fire suppression system does not op$ ration of the diesel generators.
affect the function or Fires in the relay room vill be prevented from causing fire suppression system.
spurious operation of the CO2 3.
Is the margin of safety as defined in the basis for any Technical Specification reduced?
N_0.
Reason:
This modification does not affect the Tech.
Specs on availability of AC power sources 3/4.8.1.1 & 3/4.8.1.2.
DUQUESNE LIGHT COMPANY Page 17 Beaver Valley Power Station Docket No. 50-334. License No. OpR-66 DESIGN CHANGE NO. 695 LAG COMPENSATION FOR RCS AT AND TAVG SUMMATORS i
This modification will wire in a lag compensation to filter process noise in the reactor coolant system protection loops AT and Tavg summators. Spurious trips are due to the fast response of Rosemount RTD's which replaced the slower Sostman RTD's. The lag units will be wired in accordance to AD 8-2 Application Data for Special Lag Unit. The lag compensation units will add approximately 1.2 seconds to the total response time. This will provide sufficient filtering to prevent spurious trip signals without exceeding the required response time for the overtemperature aT reactor trip listed in Technical Specification Table 3.3-2.
i CONCLUSION - SAFETY EVALUATION This modification is considered to be safe and does not present an unreviewed safety question.
A change to the Technical Specifications will be required.
The filtering provided by the lag units will be set so that the required response time of the overtemperature aT reactor trip will not be exceeded.
The total response time of the OT AT trip includes; 1) bypass loop fluid transport and thermal capacity effects, 2) RTD sensor response time, 3) trip circuit channel electronics delay time, 4) reactor trip breaker delay time and
- 5) gripper release time.
Two seconds are allowed for the effect of the RTD bypass loop per Westinghouse Startup Procedure DLW-SU-5.8.1 and Duquesne Light Start-up Test BVT-1.1-6.-l. 2.
Another 2 seconds are assumed for RTD sensor response time and filtering time. And the analyses in Chapter 14 of the UFSAR assume an additional 2-second delay time between the time the OTaT reactor trip setpoint is reached and the time the rods begin to fall. Therefore, the total time delay including the bypass loop transport time must be limited to 6 seconds.
The trip response time is verified in BVT 1.3-1.1.8.
The acceptance criteria is a maximum of 4 seconds for the sum of.the sensor response time, the channel time, the reactor trip breaker delay, and the gripper release time. Continuing to meet the acceptance criteria of BVT 1.3-1.1.8 assures that there will be at most 6
seconds from the time the reactor coolant system reaches an overtemperature aT condition and the rods begin to fall. This is consistent with the chapter 14 accident analyses The safety evaluation was reviewed and accepted at OSC Meeting BV-OSC-46-85.
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DUQUESNE LIGHT COMPANY Page 18 Beaver Valley Power Station Docket No. 50-334. License No. OpR-66 BASIS FOR SAFETY EVALUATION 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 Updated Final Safety Analyses Report (FSAR) increased?
g Reason: This modification will not result in exceeding the assumed response time in the UFSAR for accidents which require the overtem eratur: AT reactor trip. The accidents analyzed in the UFSAR which require the OTAT trip include the slow rod withdrawal at power 14.1.2, boron dilution at full power in manual coritrol 14.1.4, loss of load 14.1.7 and excessive load increasa 14.1.10.
The response time is measured during MSP 1.14
& MSP 1 15 and the acceptance criteria is in BVT 1.3-1.1.8 which will assure that the required response time listed in the Technical Specifications will continue to be met.
2.
Is the possibility for an accident or malfunction of a different type than previously evaluated in the Updated Final Safety Analysis Report created?
M Reason: The function of the AT and Tavg summators in the reactor protection system (RPS) remain unchanged. This modification does not compromise the redundancy and separation of the RPS.
3.
Is the margin of safety as defined in the basis for any Technical Specification reduced?
Reason: The total trip response times listed in Tech. Spec. Table 3.3-2 will not change only the equation for calculating the setpoint in Table 2.2-1.
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DUQUESNE LIGHT COMPANY pag, 19 Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 DESIGN CHANGE NO. 702 CR-27 LOAD CELL SYSTEM REPLACEMENT The purpose of this design change is to replace the existing load cell on the fuel building crane (CR-27), with a new system which vill perform the same function as the existing equipment.
The existing equipment is being replaced because it is obsolete, and to allow for future spare part procurement.
CONCLUSION - SAFETY EVALUATION This design change is considered safe and no unreviewed safety question is involved. This is because the new equipment vill duplicate the existing equipment in its function, without adding any new types of malfunctions to the system.
The safety evaluation was reviewed and accepted at OSC Meeting BV-0SC-56 ' 5 i
d BASIS FOR SAFETY EVALUATION 1.
Is the probability of an occurrence of the consequences of an accident or malfunction of equipment important to safety as previously evaluated in the Updated Final Safety Analysis Report (FSAR) increased?
NO.
Reason:
This design change is an exact replacement for existing equipment. The function of the equipment will not change.
The analyses in the Updated FSAR sections 9.12.2.3 and 14.2.1 are still valid.
2.
Is the possibility for an accident or malfunction of a different type than any previously evaluated in the Updated Final Safety Analysis Report created?
NO.
Reason:
The new equipment will have the same function as the existing equipment. The failures discussed in the Updated FSAR vill apply to the new equipment and no new type of failure vill be created.
3.
Is the margin of safety as' defined in the basis for any Technical Specification reduced?
NO.
Reason:
The basis for Technical Specification 3/4.9.7 vill not be affected by this design change.
DUQUESNE LIGHT COMPANY Page 20 Beaver Valley Power Station Docket No. 50-334, License No. OPR-66 Operating Manual Chapter 56C, " Alternate Safe Shutdown From Outside Control Room" To comply with 10 CFR 50, Appendix R, Section III.G, " Safe Shutdown Capablity",
OM Chapter 56C,"
Alternate Safe Shutdown From Outside the Control Room" was generated and issued.
To comply with Section III.G, an alternative shutdown methodology was developed to show an equivalent level of protection to that required of the rule and to demonstrate the capability to achieve safe shutdown given a fire event in any one fire area of the plant. The overall objectives and logic for achieving safe shutdown were based on the following considerations:
1.
Minimizing the number of powered components necessary for hot shutdown and the subsequent cooldown.
2.
Maximize the use of localized manual operation for control of all parameters during the implementation of this procedure such that the field operators should achieve stable hot shutdown conditions in close proximity to their assigned areas.
3.
Fire-induced spurious signals on plant equipment due to hot shorts, open shorts and shorts to ground will be precluded by removing 120 VAC to the slave relays and de-energizing all MOV's in the required position to achieve plant cooldown to shutdown.
4.
Induce Loss of Air condition to fail air-operated valves to their fail-safe position.
In the event of an accident during implementation of 0.M. 1.56C the consequences of that accident may be increased due to the fact that plant parameter control is based mainly on localized manual operation of various components.
Due tu mass de-energization of many components and the defeating of solid state outputs, the timeliness of actuation of such components is greatly increased in the event of any other accident not related to the fire.
However, Appendix R and this procedure assume that no postulated accident (other than station blackout) occurs during the alternate safe shutdown and it should be understood that these procedures are bounded by the BVPS Unit 1
" Station Blackout" emergency operating procedure.
Opening DC Switchboards 1 and 2 main supply breakers to DC Heinemanns provides a quicker, more reliable method of defeating DC control power to emergency 4KV and 480V busses.
The intent of OM 56C.4.C procedure remains unchanged.
Portable ventilation units are utilized to maintain normal and emergency switchgear areas temperatures within operable limits.
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DUQUESNE LIGHT COMPANY Page 21 Beaver Valley Power Station Docket No. 50-334. License No. OpR-66 Opening of fire doors between Switchgear areas and outside doors of diesel generator rooms will not increase the chances of fire spreading from the cable spreading or Process Room areas. A continuous fire barrier attendant.is established by this procedure where fire doors are blocked open. Portable ventilation units are used to regulate temperatures of emergency and normal switchgear areas.
No unreviewed safety question exists since the requirements of Appendix R,
Alternate Safe Shutdown capability are met by this procedure and the below listed BVPS Unit 1 Technical Specifications are permitted to be violated per 10 CFR 50.54(x).
Intentional violation of any Technical Specification will reduce the margin of safety.
A number of steps within 0.M. 1.56C will violate the Technical Specifications, (i.e.,
minimizing loads to preclude spurious fire induced actuations).
As permitted by 10 CFR 50.54(x)(1), these actions are authorized and are necessary to mitigate the effects of a fire that is beyond the design bases of this plant to ensure that the methods employed will achieve a stable hot standby condition and a subsequent plant cooldown.
The following is a list of BVPS Unit 1 Technical Specifications that will most likely be violated during implementation of 0.M.1.56C.:
Tech. Spec. Deviations T.S. 3.1.1.1 Shutdown Margin - Tavg > 200*F T.S. 3.1.1.2 Shutdown Margin - Tavg $ 200*F
- Reason for deviation:
A Boron concentration may or may not be determined depending on the feasibility for containment entry to obtain a coolant sample,
- Justification:
Appendix R only requires a 1% shutdown margin for safe shutdown. There have been calculations performed to show that there will be a 1% shutdown margin at < 200*F based on EOL reactor trip from full power and the amount of RWST water injected into the RCS to compensate for system shrink during cooldown.
The major conservatisms that are included are 4
the most reactive stuck rod and the 100 ppm allowances which are not required to be used (based on Appendix R). This further ensures the 1%
SDM at 5 200*F and > 200*F.
IAs justified by letters N01SLC:366 dated 10/28/82, NRC SER for Appendix R dated 1/5/83, and NDISLC:1116 dated 8/7/84.
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Page 22 DUQUESNE LICHT COMPANY Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 T.S. 3.1.2.2 Boration Flowpaths - Operating
- Reason for Deviation:
The boration flowpath from the Boric Acid Tanks is rendered inoperable due to the act of minimizing loads and defeating Station Air.
- Justification The boration flowpath from the RWST is " hardened" by de-energizing that flowpath's MOVs in the.open positions as required by 0.M.
1.56C.
T.S. 3.1.2.4 Charging Pumps - OPERATING
- Reason for deviation:
The de-energization of the fire affected train will render that train's charging pump inoperable.
- Justification:
The charging pump for the operating train will be maintained operating.
In the event that the operating pump fails, the swing pump will be utilized.
T.S. 3.3.2.1 ESF Instrumentation
- Reason for deviation:
The procedures in 0.M. 1.56C have the operations personnel defeat Solid State Protection outputs by removing 120 VAC to the slave relays to preclude fire induced spurious signals.
- Justifications a.
Appendix R assumes that no postulated accidents occur during such postulated fires.
b.
The hardening techniques utilized by 0.M.
1.56C will place the required components in the desired states (i.e., de-energizing MOVs, operating pumps with DC control power removed, etc.)
such that any spurious outputs from solid state will not produce the designed actuations.
(The procedures in 0.M. 1.56C are bounded by the BVPS Unit 1 " Station Blackout" emergency operating procedure).
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Page 23 DUQUESNE LIGHT COMPANY Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 T.S. 3.3.3.1 Radiation Monitoring Instrumentation T.S. 3.3.3.9 Radioactive Effluent Monitors
- Reason for deviation:
Due to the minimizing of loads, Radiation Monitor pumps that support various process monitors will be de-energized.
- Justification:
There will be no releases during implementation of this procedure because:
a.
Ventilation is de-energized and isolated b.
Station Air is defeated c.
There is no postulated accident that is occurring during the implementation of 0.M. 1.56C (based on Appendix R conditionc T.S. 3.3.3.3 Seismic Monitoring Instrumentation
- Reason for deviation Due to the action of minimizing loads, the power that supplies such instrumentation will be de-energized.
- Justification:
It is assumed (based on Appendix R) that no other accident (i.e., Design Basis Event) is occurring during implementation of 0.M.
1.56C.
T.S. 3.5.1.2 Reactor Ccolant Loops - Hot Standby T.S. 3.4.1.3 Reactor Coolant Loops - Shutdown
- Reason for deviation:
Due to the de-energization of normal 4KV power, all reactor coolant pumps will be de-energized, also, RHR is not in-service due to no CCR.
- Justification:
I BVPS has shown the capability for natural circulation cooldown which is the mode of RCS cooling utilized by 0.M.
1.56C.
In modes 4 and 260*F, Part 4 of the 0.M.
1.56C procedures outline the method for a water-to-water heat exchange mode to cooldown to Mode 5 (DLCo. is not committed to using Part 4 but will show the capability).
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Paga 24 DUQUESNE LIGHT COMPANY Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 The following Technical Specifications are also violated due to the minimization of loads to preclude spurious fire induced actuations:
T.S. 3.4.6.1 Leakage Detection Systems
- Justification:
No postulated accidents are occurring during implenentation of 0.M. 1.56C. based on Appendix R assumptions.
T.S. 3.4.1.1 PCRVs
- Justification Overpressure protection is not needed during implementation of 0.M. 1.56C due to cooldown, depressurization and minimal make-up flow.
ECCS Subsystems
- Justification No postulated accidents are occurring during implementation of 0.M.
1.56C, based on Appendix R assumptions.
T.S. 3.6.2.1 CNMT Quench Spray System T.S. 3.6.2.2 CNMT Recirculation Spray System T.S. 3.6.2.3 Chemical Injection System
- Justification No postulated accidents are occurring during implementation of 0.M.
1.56C, based on Appendix R assumptions.
T.S. 3.7.1.2 Auxiliary Feedwater System
- Justification:
The Steam-Driven AFW Pump will be used until its capacity is too low, then a motor-driven AFW pump powered from the unaffected Train will be used. Also the Dedicated AFW Pump will be used when WT-TK-10 has been depleted.
T.S. 3.7.3.1 Component Cooling System
- Ju s t i fic a t i Jn CCR is a non-essential load as letdown is isolated, RCP's are de-energized, etc.
Page 25 DUQUESNE LIGHT COMPANY Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 T.S. 3.7.4.1 River Water System
- Justification:
The RW pump that is powered by the unaffected train will be operating.
In the event that the running pump fails, the swing pump may be used. Additional backup capacity is available by manual lineup of Auxiliary River Water.
T.S. 3.7.7.1 Control Room Emergency Habitability Systems
- Justification:
For the procedures within 0.M. 1.56C these systems are not required since the control room will be uninhabited.
T.S. 3.7.8.1 Supplemental Leak Collection And Release System
- Justification:
Based on Appendix R, no postulated accidents are assumed to occur during 0.M.
1.56C implementation. Therefore, since no ESF equipment will be operating, thus no leakage, the S.L.C.R.S. is not required.
T.S. 3.7.13.1 Auxiliary River Water System
- Justification:
Although the Auxiliary RW pump will be de-energized, due to de-energization of the stub bus to minimize the available Train's loads, it still has the capability to be manually loaded to the bus, if required, and its discharge MOV manually opened.
T.S. 3.8.1.1 A.C. Power System - OPERATING T.S. 3.8.2.1
- Reason for deviation:
To mitigate the possibility of spurious fire induced actuations while achieving plant shutdown, one redundant train is " hardened" while the other train that may potentially be affected by tie fire is de-energized. The affected Train's Diesel Generator is de-activated and a loss of AC power to its normal and emergency busses and DC control power to its tie breakers are induced.
The required train is hardened by maintaining its Diesel Generator in service to power equipment required for achieving
DUQUESNE LIGHT COMPANY Page 26 Beaver Valley Power Station Docket No. 50-334, license No. DPR-66 safe shutdown and by de-energizing and aligning valving to positions required for achieving safe shutdown to cold shutdown conditions.
- Justification:
De-energization of one redundant train is permitted by Appendix R and because the FSAR accounts for only one complete Train of ESF components to be used for achieving safe cold shutdown conditions.
These procedures ensure one complete train is maintained in a safe condition for plant shutdown purposes by hardening that train in accordance with Appendix R requirements and maintaining diesel generator power. Although the Vital Busses I, II,
- III, IV are not used in 0.M. 1.56C, they are maintained in service while being powered from the Station Batteries through the inverters.
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T.S. 3.8.2.4 OC Control Power
- Reason for Deviation:
Defeat the DC Control power to prevent spurious fire induced activation of 4 KV and 480 VAC emergency ESF equipment.
- Justification:
These changes comply with Appendix R guidelines to protect the public.
OM Chapter 568. " Fire Prevention and Control Procedures" To comply with Section III.G of Appendix R " Safe Shutdown Capability", OM Chapter 568 nas been revised and reorganized to add pre-fire plan strategies for the new onsite and offsite fire areas that have been created under Appendix R guidelines for BVPS Unit 1,
and added new fire strategy procedures to incorporate the BVPS Unit 1 Appendix R Electrical Circuit Analysis for safety related systems and components.
These procedures cannot accommodate every possible combination of condition that might occur as a result of a type of fire taken credit for in Appendix R Analysis.
However, these new procedures based on the circuit analysis are an additional improvement over the existing recovery procedures.
They provide instructions for bringing plant systems under control that are affected by a fire analyzed in the BVPS Unit 1 Appendix R analysis.
The recovery procedures are based on worst case conditions (i.e., loss of offsite power coincident with the postulated fire event). The procedures are intended to provide supplemental guidance as to which train to utilize, what components can be reliably operated from the control room and which l
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DUQUESNE LIGHT COHPANY Beaver Valley Power Station Docket No. 50-3 34, License No. DPR-66 components to locally verify or re-align (ie, components that must be operated or aligned but may not be able to be operated from the control room). Based on Appendix R, safe shutdown capability must be demonstrated. All that is required to be demonstrated is the capability to operate equipment required for safe shutdown using these procedures.
Based on Appendix R, no single or concurrent failures other than those directly attributable to the postulated fire are considered, with the exception of a loss of offsite power.
These procedures do not reduce the margin of safety as defined in BVPS Unit 1 Technical Specifications. A fire itself will most likely reduce the margin of safety. The utilization of the procedures will be dependent on the severity of the fire, the location of the fire or when the control room experiences spurious fire induced actuations of essential components or in-dications. Then components may be de-energized by the procedures so that i
fire induced faults will not adversely affect the supply bus, or inhibit local manual operations or fire fighting efforts.
These procedures allow one train of safety-related equipment to be operated to maintain the plant in a safe condition.
No unreviewed safety question exists.
OM Chapter 7.4, Procedure A.T., "Off-Normal Blender Boration Or Dilution for Shutdown Operation This revision to procedure A.T. of BVPS Unit i Operating Manual Chapter 7 added administrative controls on reactivity changes by assuring proper volumes are considered when diluting or borating the Reactor Coolant System during 0FF-NORMAL Volumetric conditions via the dilution /boration flow paths used during Modes 4,5 and 6.
This revised procedure is intended to prevent an inadvertant over dilution or boration event.
The procedure assures an adequate shutdown margin is maintained via frequent plant chemistry sampling of the RCS.
The procedure ensures compliance with BVPS Unit i Technical Specifications.
i No unreviewed safety question is involved.
OM Chapters 53A and 53B, Upgraded Emergency Cperating Procedures The upgraded Emergency Operating Procedures (EOPs) for BVPS Unit I were generated based on the reanalysis of transients and accidents as described j
and clarified in item I.C.1 of NUREG-0737, BVPS Unit 1 Updated Final Safety Analysis Report (UFSAR), and the Westinghouse generic Emergency Response Guidelines (ERCS), Rev. 1, dated September 1, 1983, with their background documents. The upgraded EOPs are used to direct the operators actions in mitigating the consequence s of transients and accidents without the need to diagnose an event in order to maintain the plant in a safe condition. The EOPs are intended to follow the ERGS as closely as possible in order to take full credit for the analysis effort, the human factors principles applied
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Page 28 DUQUESNE LIGHT COMPANY Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 and the function and task analysis effort which has formed the basis for the operator information and control needs. Various steps of the EOPs are intended to deviate from corresponding steps of the ERCS due to:
1.
Known plant conditions and equipment differences between the ERG reference plant and BVPS Unit 1.
2.
Licensing committments for BVPS Unit 1.
3.
Resolutions of deficiencies identified by the BVPS E0P Verification and Validation Programs.
4.
Valid recommendations obtained from plant operator experience.
All minor deviations have been identified and documented and the EOPs have been written, verified and validated in accordance to the BVPS Unit No. 1 Procedures Generation Package for E0Ps, Docket No. 50-334, submitted to the NRC on July 1, 1984. No deviations from the ERGS that are significant to safety exist in the E0Ps. The term significant deviation is defined in J. J. Carey's letter to the NRC, dated March 14, 1984.
As explained above, the EOPs closely follow the ERGS and in order to take credit for the accident analysis and Safety Evaluation Report (SER) for the WOC-ERGS.
An SER for the basic version (Revision 0 ) of the ERGS has been reviewed by the NRC, The NRC comments in response to the SER have been incorporated into the Revision 1 issue of the WOC-ERGS and BVPS-EOPs.
i An SER has been developed by Westinghouse for the Revision 1 ERGS and that SER is presently under NRC review.
Because no significant deviations from the Revision 1 ERCS have been made in the EOPs, the EOPs can take credit for the ERG SER for the Revision 0 and Revision 1 ERCS.
The Revision 0 ERG SER describes the actions for recovering from or mitigating the consequences of accidents covered by the ERGS.
Throughout these E0Ps. steps are outlined which will result in violations of technical specifications. Many of these violations will result in the margin to safety as described in the tech spec basis being reduced. These violations are unavoidable and acceptable.
For instance, during a reactor trip with aux. feed delivering water to the steam generators from the Primary Plant Domineralized Storage Tank, it is expected that the tanks level will i
drop below tech spec limits. Obviously, it is not desirable to stop flow from this tank in order to satisfy tech specs.
The tech specs violated by these procedures are consistant in two ways.
First, all violations described by these procedures aid to protect the health and safety of the public by attempting to restore the plant to a stable, safe condition. Second, all violations described by the BVPS procedures are described by the Westin'ghouse Owners Group ERGS.
l Page 29 DUQUENSE LIGHT COMPANY Beaver Valley Power Station Docket No_ 50-334, License No. DPR-66 There are some procedure steps described by the ERGS which would cause violation of BVPS Tech Specs but not cause violation at the WOG Reference Plant. For instance, during ES-3.2, " Post SGTR Cooldown Using Blowdown",
reliance on the ERG's could result in violation of T.S. 3.4.9.1 - Reactor Coolant System Pressure / Temperature Limits. This procedure is a lower level emergency with the plant in a basically stable condition. This violation would result at BVPS from a very limiting cooldown curve due to a reduced NDRDT.
In a case such as this, the BVPS procedures stay within the limits of Tech Specs.
10 CFR 50.54 (X) permits tech spec violation when necessary to protect the health and safety of the public.
BVPS Unit 1 Station Administration Procedures Chapter 4 further describes the circumstances allowing violation of tech specs. The WOG Executive Volume Generic Issues - Technical Specification Violations section notes that the NRC " acknowledged that it may 'oe necessary in some emergency situations to take actions which are, or can lead to, violation of Technical Specifications." Therefore, as a result of the above summary, so unreviewed safety question exists with the BVPS EOPs.
Corrective Maintenance Procedure CMP 1-15CC-E-1A-B-C-1M, Revison 4, Tube Leak Check of Reactor Plant CCR Heat Exchangers, Field Revision 85-M-06.
As evaluated and developed by BVPS, Unit No. 1 Engineering, the existing station approved procedure allows a maximum number of 110 cubes in the CCR heat exchanger to be plugged. Under the guidance of BVPS, Unit No. 1, Nuclear Engineering Department per Engineering Memorandum 71 845, the procedure was field revised to allow 113 tubes to be plugged provided administrative changes are implemented to limit the differential pressure across the tubes to 10 psid.
Administrative changes were implemented by entering in the Log L3-10 of the BVPS Unit No. 1. Operating Manual, Chapter 54, to notify the Nuclear Shift Supervisor if differential pressure exceeds 10 psid. No unreviewed safety question was involved with this procedure revision.
Maintenance Surveillance Procedures (MSP) 1.17, 1.18, 1.19 and 1.20; Revision 0;
" Reactor Trip Breaker RTA (RTB, BYB, and BYA) Undervoltage Trip Force Test These new procedures were implemented each'to perform an undervoltage trip force test in accordance with IE Bulletin 85-02 requirements on the I
reactor trip breakers identified as RP-BK-RTA, RP-BK-RTB, RP-BK-BYA and RP-BK-BYB.
The test consists of loading the trip bar with a weight of 20 oz.
- 1 oz., applying a 48 VDC source to the undervoltage coil and manually closing the breaker. Each test is performed three consecutive times, and results of repetitive tests are documented in the procedure.
These bi-monthly undervoltage trip force tests assure proper and reliable operation of the reactor trip breakers and the results of the test can be evaluated to determine if any corrective maintenance le required. No unreviewed safety question was involved with this new procedure.
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Page 30 DUQUESNE LIGHT COMPANY Beaver Valley Power Station Docket No. 50-334, License No. DPR-66 Maintenance Surveillance Precedure (MSP) 2.03 (4) (5) (6), Revision 27 (26)
(26) (25) Power Range Calibrations.
This revision to MSP 2.03 (4) (5) (6) changed the Flux Rate Trip Setpoint from 4.8% to 2.5% Power based on Tech Bulletin NSID-TB-85-13.
The change to the Flux Rate Trip Setpoint is in the more conservative direction and BVPS Unit 1 UESAR Section 7.2.1.1.1, " Nuclear Overpower Trips" and 14.1,
" Core and Coolant Boundary Protection Analysis" are still complied with.
Also BVPS Unit i Technical Specification 3.3.1.1 refers to the setpoint as a maximum. No unreviewed safety question was involved with this procedure revision.
Corrective Maintenance Procedure (CMP) 1-6RP-BK-UVTA-II (2I) Revision O (0)
Train A (B) Reactor Trip Breaker UV Coil Time Response Test This is a new procedure to perform a time response test for the UV coil of a new or replaced Reactor Trip Breaker.
" Instrumentation and Controls" references the BVPS Unit 1 Technical Specifications for setpoints and actions required. This test is being performed to satisfy the requirements of Technical Specification 3.3.1.1.
It performs this test within the guidelines of Technical Specifications 3.3.1.1 and 3.3.1.2.
No unreviewed safety question was involved with this procedure revision.
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Page 31 DUQUESNE LIGHT COMPANY Beaver Valley Power Station Docket No. 50-334. License No. OPR-66 Specific Nuclide Activity Determination (Reactor Coolant System)
The changes involved greater decay times when counting Reactor Coolant samples for radioactivity.
When the shorter-lived but more abundant radioisotopes decay, an improvement in sensitivity occurs for the longer-lived but less abundant isotopes.
Check of decay times and half-lives serves as further verification of the identity of the isotope.
The change incorporated improvements suggested during the 1985 INPO Evaluation and NRC Inspection 84-24.
No changes were made to sample frequency nor to specifications on the amount of cadioactivity allowed. (BV-OSC-41-85).
Secondary Water Specifications This change implemented new specifications and analysis requirements mandated by NRR Generic Letter 85-02. More specifications were added, and others were made more stringent.
Actien statements requiring power reductions and plant shutdowns for exceeding certi.in limits were also added. Specification changes made were in accordance with EPRI-NP-2704 and Westinghouse SGTD-5.1.1-4468.
(BV-OSC-56-85)
Diesel Fuel Oil Specification The pour point test was deleted since it was not required by Reg. Guide 1.137 (BV-0SC-58-85)
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