ML20216H394
| ML20216H394 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/15/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20216H368 | List: |
| References | |
| NUDOCS 9804210126 | |
| Download: ML20216H394 (4) | |
Text
UNITED STATES
)
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30e064001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.911 AND on TO FACILITY OPERATING LICENSE NOS. DPR 88 AND NPF-73 DUQUESNE LIGHT COMPANY OHIO EDISON 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
By letter dated March 16,1998, the Duquesne Ught Company (the licensee) submitted a request for changes to the Beaver Valley Power Station, Unit Nos.1 and 2 (BVPS-1 and BVPS-2),
Technical Specifications (TSs). The requested changes would add a new Limiting Condition for Operation (LCO) 3.0.6 to TS Section 3/4.0, " APPLICABILITY." The new LCO 3.0.6 would provide specific guidance for retuming equipment to service under administrative control to perform testing required to demonstrate OPERABILITY.
2.0 EVALUATION The NRC's improved Standard Technical Specifications (ISTS) for Westinghouse Plants (NUREG-1431, Revision 1) includes a provision (TS 3.0.5) that establishes an allowance for rr, storing equipment to service under administrative control when the equipment has been removed from service or declared inoperable to comply with ACTION statement requirements.
The sole purpose of this provision is to permit testing required to demonstrate the equipment's OPERABILITY or the OPERABILITY of other equipment. The ISTS provision provides an exception to the requirements of ISTS TS 3.0.2, which would otherwise requke compliance with the provisions of the applicable ACTION statement requirements.
The present BVPS-1 and BVPS-2 TSs do not include a p.svision such as is included in ISTS TS 3.0.5. Therefore, the licensee has proposed to add a new TS 3.0.6 to the BVPS-1 and BVPS-2 TSs. The proposed new TS 3.0.6 would be as follows:
l 3.0.6 Equipment removed from service or declared inoperabe to comply with ACTIONS may be retumed to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to Limiting Condition for Operation 3.0.1 for the system retumed to service under administrative control to perform the testing required to demonstrate OPERABILITY.
9804210126 900415 PDR ADOCK 05000334 P
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s 2-BVPS-1 and BVPS-2 are both currently in cold shutdown. The licensee has identified the following examples for which the proposed new TS 3.0.6 would be applicable and needed to permit restart. As the first example, BVPS-2 had been experiencing seat leakage in all three pressurizer power-operated relief valves (PORVs) during plant operation before the current
'I outage. The licensee repaired all three PORVs during this outage. When the repair work was completed, a temporary operating procedure (TOP) was written to ensure all administrative controls would be in place before pressurizing the plant for a post maintenance test. For this test, the PORVs must have pressure in order to be stroke tested. During review of the TOP, the licensee's Onsite Safety Committee (OSC) identified that TS 3.0.1 would not allow the reactor coolant system (RCS) to be repressurtzed with all three PORVs inoperable (i.e., without normal '
J overpressure protection system operable). The current BVPS-2 TSs create a dilemma in that BVPS-2 cannot be pressurized without the PORVs being operable and the PORVs cannot be tested to demonstrate their operability without pressurizing the BVPS 2 RCS. Acmng proposed TS 3.0.6 would resolve this dilemma.
A second example of this problem with TS 3.0.1 is TS 3.1.3.3, " Position Indication System.
Shutdown." TS 3.1.3.3 requires that the group demand position indicators be operable and capable of determining the demand position for each shutdown or control rod not fully inserted within 2 steps. TS 3.1.3.3 is applicable in MODES 3,4, and 5 when the reactor trip system breakers are in the closed position. The action statement for TS 3.1.3.3 requires opening of the reactor trip system breakers when the requirements of TS 3.1.3.3 are not being met. TS 4.1.3.3 requires verification of the group demand position indicators by moving the associated control rods at least 10 steps in any one direction at least once per 31 days when the RCS pressure is greater than 400 psig. Plant startup will not be permitted if TS 4.1.3.3 has not been completed within the last 31 days since the action statement of TS 3.1.3.3 prohibits closing of the reactor trip breakers to perform the testing necessary to demonstrate equipment operability. BVPS-1 is currently in this situation. Adding proposed TS 3.0.6 would resolve this dilemma.
Therefore, the licensee has proposed the addition of new TS 3.0.6 and its associated bases to resolve these and other potential similar dilemmas. The NRC staff has reviewed the licensee's propot,al to add the new TS 3.0.6 and has determined that this addition is consistent with current NRC staff guidance as reflected in the NRC's ISTS (NUREG-1431, Revision 1). Therefore, the proposed change is acceptable.
3.0 EXIGENT CIRCUMSTANCES
On March 16,1998, the licensee requested that the proposed license amendment be processed as an exigent TS change in accordance with 10 CFR 50 91(a)(6). Exigent processing was requested because both BVPS-1 and BVPS-2 are in cold shutdown (Mode 5) and both units require issuance of this amendment t'efore restart. The licensee's staff has stated to the NRC staff that the plant will be ready to begin restart on April 21,1998. It was only during an extensive review of the TS surveillance requirements during the current outages that the licensee recognized that the current TSs do not allow changing plant conditions under administrative control to permit testing necessary to oemonstrate equipment operability. When it was recognized that a TS change was necessary to resolve this issue, a license amendment request was prepared in a timely mannet. Therefore, we concludo that time does not permit the
' Commission to publish a EnderM Register notice allowing 30 days for prior public comment and a license amendment pursuant to 10 CFR 50.91(a)(6) should be processed.
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4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
The Commission's regulations in 10 CFR 50.92 state that the Commission may make a final determination that a license amendment involves no significant hazards considerations if operation of the facitity in accordance with the amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the
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possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety, in the March 16,1998, application, the licensee provided the following analysis:
1.
Does the change involvo a significant increase in the probability or consequences of an accident previously e valuated?
The proposed change does not affect the operation or design of the plant in any way.
Operation of plant equipment under this change will not differ in any way from its normal operational mode. The normal operation of plant equipment is not a precursor to any accident. The purpose of tests performed using this change is to demonstrate that required automatic actions are carried out. Equipment will be operated under administrative control for only a short period of time. If it should be required, personnel will be immediately available to take appropriate manual action. Therefore, operation of equipment under this change is not expected to increase the probability or consequences of an accideat previously evaluated.
2.
Does. the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The proposed testing allowance will not change the physical plant or the modes of plant operation defined in the operating license. The change does not involve the add.ition or modification of equipment nor does it alter the design or operation of plant systems. Therefore, operation of the facility in accordance with the proposed amendment will not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
Dces the change involve a significant reduction in a margin of safety?
Equipment will be operated under administrative control for only a short period of time.
If it shou! ' he required, personnel will be immediately available to take appropriate manual action. The purpose of the testing is to restore required equipment to an OPERABLE state which increases the automtic protection available and reduces the reliance on the compensatory measures puided by ACTION statements. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based upon the above considerations, the staff concludes that the amendment meets the three criteria of 10 CFR 50.92. Therefore, the staff has made a final determination that the proposed amendment does not involve a significant hazards consideration.
5.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.
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6.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined i
that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has made a final finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (63 FR 14142). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmentalimpact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the hecith and safety of the public.
Principal Contributor: D. Brinkman Date:
April 15, 1998
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