ML20236S288
| ML20236S288 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 07/13/1998 |
| From: | DUQUESNE LIGHT CO. |
| To: | |
| Shared Package | |
| ML20236S282 | List: |
| References | |
| NUDOCS 9807240241 | |
| Download: ML20236S288 (35) | |
Text
s ATTACHMENT A-1 Beaver Valley Power Station, Unit No. 1 Proposed License Amendment Request No. 257 I
UFSAR SECTION 9.7.2 REVISION l
l The following is a list of the affected pages:
l l
Affected UFSAR Pages:
9.7-7 9.7-8 l
9807240241 980713 PDR ADOCK 05000334 p
e Beaver Valley Power Station, Unit No. 1 License Amendment Recuest No. 257
'Present and Proposed Words for BVPS-1 UFSAR Section 9.7.2 l
"Rivter Water Pumps and Enaine-Driven Fire Puno-Intake Structure" Present UFSAR Wordina River Water Pumns and Encine-Driven Fire Pumn-Intake Structure There are no equipment or floor drains located in the intake structure.
There are no precautions necessary to prevent flooding in the event of a major pipe rupture in any of the pressure water lines in the pump cubicles because open cubicle access doors will permit excess water to flow out of the cubicles.
The pump cubicles are structurally protected from ingress of water from the probable maximum flood.
Proposed UFSAR Wordina River Water Pumos and Enaine-Driven Fire Pumo-Intake Structure Each Intake Structure Pump cubicle has an emergency-powered sump pump which is controlled by a float switch.
The external flood protection doors leading into each Intake Structure Pump Cubicle are normally open with their associated security / fire doors normally closed.
The interconnecting flood protection doors that are located between the pump cubicles are normally closed with their seals depressurized, along with their associated security / fire doors normally closed.
These door seals will be pressurized in the event' of an external flood or for seal testing purposes.
This arrangement is designed to protect the interconnecting cubicles from the consequences of a major pipe rubber expansion joint failure.
l
t ATTACHMENT A-2 Beaver Valley Power Station, Unit No. 2 Proposed License Amendment Request No. 128 UFSAR SECTION 3.6.B.1.3.4.2 REVISION The following is a list of the affected pages:
Affected UFSAR Pages:
3.6-12
)
I l
1 L
l 1
i l
L__--_--___-___________
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i BBavor Valloy Powar Station, Unit No. 2 License Amendment Recuest No. 128 l
Present and Proposed Words for BVPS-2 UFSAR section 3.6B.1.3.4.2, " Internal Floodina"
" Intake structure" l
Present UFSAR Wording Intake scructure The intake structure is shared between Beaver Valley Power Station -
Unit 1'(BVPS-1) and Beaver Valley Power Station - Unit 2 (BVPS-2). It has four separate cubicles, three of which contain one of the BVPS-2 service water pumps. The pump motors and all piping are located above the operating deck in each cubicle, which is roanable of beinal sealed to protect against external floods.
The postulated piping failure, which causes the highest flood level above the operating deck, is a moderate energy crack in a 30-inch service water line. The service water pump motor in the affected cubicle would then be inoperable. However, three service water pumps are provided (Section 9.2). One service water pump is sufficient for emergency shutdown and loss of one pump during normal operation does not require immediate plant shutdown. The Technical Specifications (Chapter 16) govern the length of time BVPS-2 can operate with one of the redundant service' water flow paths out of service. The length of time allowed is sufficient for the operator to align the third (spare) service water pump electrically and hydraulically to the flow path of the inoperable pump. As discussed in Section 3.6B.l.3.1, Single Failure Application, single failure of the operating service i
water pump need not be assumed following a piping failure, since the i
service water system (SWS)
(moderate energy) is designed to QA Category I and Seismic Category I standards and the pumps are powered from water cumo need not be assumed followina a olvina failure since the service water system (SWS)
(moderate - enerav) is desianed to OA Cateaorv I and Seismic Cateaorv I standards and the Dumos are covered i
from the Class lE buses. Therefore, loss of one pump due to flooding has no adverse safety considerations.
Proposed UFSAR Wording l
(Add the following words to the bottom of the above section)
(since the Intake structure pump oubioles' are shared between BVPS-1 and BVPS-2, internal flooding concerns have been evaluated.
The external flood protection doors leading into each Intake structure Pump Cubiale are normally open with their associated security / fire doors normally closed.
The interconnecting flood protection doors i
l that are located between the pump cubicles are normally closed with I
their seals depressurised, along with their associated security / fire doors normally closed. These door seals will be pressurized in the event of an external flood or for seal testing purposes.
This arrangement is designed to protect the interconnecting cubieles from the consequences of a major pipe rubber expansion joint failure.)
B30Vcr Volloy PowOr Station, Unit No. 2 License Amendment Reauest No. 12,1 (Continued) l Note For changes in the present BVPS-2 UFSAR words, 1.
delete the underlined, bolded, italicised words, and add the underlined bolded bracketed words.
1 1
i
s ATTACHMENT B Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed License Amendment Request Nos. 257 and 128 CONFIGURATION OF INTAKE STRUCTURE DOORS REVISION A.
DESCRIPTION OF AMENDMENT REQUEST The proposed amendment would revise the Unit 1 and Unit 2 UFSAR descriptions of the Intake Structure main entrance and interconnecting cubicle doors.
This amendment is being requested in accordance with 10 CFR 50.9(c) because it has been identified that NRC approval is needed to address a new failure mode of safety related equipment
{
that had not been previously considered for Unit 1.
B.
DESIGN BASES The River Water Pumps provide cooling [ river) water to Unit 1 safety related heat exchangers.
The Service Water Pumps provide cooling [ river) water to Unit 2 safety related heat exchangers.
1 The pipes carrying the water to the heat exchangers pass through the River Water / Service Water Pump Cubicles and the Unit 1 River Water and Raw Water Systems employ rubber expansion joints. The Raw Water System supplies cooling [ river) water to Unit i non-safety related components.
Unit 1 River Water Pumps and Unit 2 Service Water pumps share cubicles in the intake structure.
The Unit 1 River Water
'A' Pump is in the
'A' Cubicle.
The Unit 1 River Water
'B' Pump and the Unit 2 Service Water
'C' Pump are located in
'B' Cubicle.
The Unit 1 River Water
'C' Pump and the Unit 2 Service Water
'B' Pump are located in
'C' Cubicle.
The Unit 2 Service Water
'A' Pump is in the
'D' Cubicle.
Each cubicle has an entrance equipped with a door used for fire protection and security access control purposes as well as a
separate flood control door equipped with inflatable seals.
The same types of doors are provided between Cubicles
'A' and
'B'.
The same types of doors l
are provided between cubicles
'C' and
'D'.
There is a solid wall between cubicles
'B' and
'C' and no door between cubicles
'B' and
'C'.
The previous Unit 1
safety analyses did not consider the potential for internal flooding due to the practice of keeping the entrance fire / security access doors open. The results of the original BVPS-1 FSAR Appendix D review had indicated there was no flooding concern since there are no high energy lines in these cubicles. Subsequent reviews have indicated that failure of the rubber expansion joints is a
flooding concern for adjacent cubicles unless the doors between the cubicles are kept closed.
t L-________-____________________
ATTACHMENT B, continutd Prcpond Lic3nso Amsndmsnt Request Nos. 257 and 128 Page 2 j
I C.
JUSTIFICATION In order to. provide protection of redundant Unit 1 River Water pumps and _ redundant Unit 2
service Water pumps the fire protection / security access and the flood control doors between cubicles
'A' and
'B' and between cubicles.'C' and
'D' will normally be kept closed.
If a flood occurs in any one of the cubicles the failures will be limited to only one pump-(train) in either. unit.
The practice of keeping the entrance fire / security access doors closed will continue.
The inflatable door seals will be pressurized only in the event of an external flood or for seal testing purposes.
.D.
SAFETY ANALYSIS These proposed revisions to the Beaver Valley Unit 1 and 2 UFSARs are being requested-to state the practices used to maintain independence,of the redundant River Water Pumps at Unit 1 and the independence of the redundant service Water Pumps at Unit 2.
Maintaining the' flood control doors and the fire / security access doors closed between the cubicles containing redundant River Water and redundant Service Water Pumps prevents the common cause failure ~ of - these pumps due to a failure of a rubber expansion joint in one of the cubicles. These doors will be opened only when a postulated internal flood could not result in two trains of the River Water System'at Unit 1 or two trains of the Service Water System at Unit 2 being adversely affected.
E.
NO SIGNIFICANT HAZARDS EVALUATION l
The no significant hazard considerations involved with the l
. proposed amendment have been evaluated, focusing on the three standards set forth in'10 CFR 50.92(c) as quoted below:
i The Commission may make a final determination, pursuant to the procedures in paragraph 50.91, that a proposed amendment to an ' operating license for a
facility licensed under l
l paragraph 50.21(b) or paragraph 50.22 or for a testing l
ll facility involves no significant hazards consideration, if 1
l operation of the facility in accordance with the proposed l
amendment would not:
(1)
Involve a significant increase in the probability or consequences of an accident previously evaluated; or 4
(2)
Create the possibility of a new or different kind of I
accident from any accident previously evaluated; or B-2
4 '
ATTACHMENT D, cantinutd Proposed Lictnno Am:nda nt R qutot Nos. 257 and 128 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 change revises the text of the UFSAR for Unit 1 and Unit. 2 to describe how protection is provided against potential internal floods in the cubicles that house the Unit 1 River Water and Unit 2 Service Water Pumps.
The previous description concluded that the Unit 1 River Water pumps were protected because open cubicle access doors will permit excess water to flow out of the cubicles.
The practice that has changed, and is described in the proposed revisions to the Unit 1 and Unit 2 UFSARs, will provide protection of the Unit 1 River Water Pumps and the Unit 2 Service Water Pumps so that no flooding event can adversely affect more than one Unit 1 or Unit 2 pump.
Therefore, it can be concluded that the proposed changes do not involve any increase in the probability or consequences of an accident previously' evaluated.
2.
Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
The effect of flooding the pump cubicles was considered in BVPS-1 to have no adverse effect because open cubicle access doors would permit excess water to flow out of the cubicles, and pipe cracks in moderate energy piping was not part of the design basis.
Revising the door arrangement described in the BVPS-1 UFSAR such that the security / fire doors are normally closed, requires that the effects of flooding be considered.
l Engineering analysis shows that a moderate energy pipe crack, (i.e.,
the BVPS-2 design basis internal flood), produces a leak rate of 1162 gpa, which results in a maximum water level of 0.82 feet, with the security / fire doors closed.
The water level in the adjacent cubicle would reach a level at 0.37 feet.
This is below the level which would cause failures of
)
the McCs in the pump cubicles.
The maximum leak rate from a failure of a Unit i rubber expansion joint in a pump cubicle would result in water l
rising to a level which would cause the McCs to be flooded and fail; therefore, maintaining the flood door between the adjacent cubicles closed limits the impact to a single train.
Failure of a single train of River Water is analyzed in the UFSAR; therefore, this change would not introduce a new or different type of accident.
B-3
1 ATTACHMENT B, continu d Proporcd LicOn00 Am:nd cnt R qu3ct'Nca. 257 and 128 Page 4 3.
Does the change involve a significant reduction in a margin of safety?
The proposed change in the Unit 1 and Unit 2 UFSARs describes how protection is provided for the Unit 1 River Water, and the Unit 2 Service Water pumps.
Protection of the Unit 1 River Water Pumps and the Unit 2 Service Water pumps is provided so that no flooding event can adversely affect more than one Unit 1 or Unit 2 pump.
Therefore, it can be concluded that the proposed changes do not involve any reduction in a margin of safety.
F.
NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION l
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 requests changes to the description of how flood protection is provided in the Intake Structure at Beaver l
Valley Power Station.
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 may change requirements with respect to installation or use of a facility component located within the restricted area or change an inspection or j
surveillance requirement; however, the category of this licensing action does not individually or cumulatively have a significant l
effect 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.
H.
UFSAR CHANGES UFSAR changes are required.
See Attachments A-1 and A-2.
I B-4 l
L__-_-____-____
ATTACHMENT C-1 Beaver Valley Power Station, Unit No. 1 Proposed License Amendment Request No. 257 UFSAR SECTION 9.7.2 REVISION Attached is the 10 CFR 50.59 evaluation that documents the unreviewed safety question.
1 i
/
10 CFR 50.59 EVALUATION WORKSHEET Plant Change or Procedure No.
BVPS-1 UFSAR Section 9.7.2 Revision No.
O Plant Change or Procedure
Title:
Update BVPS-1 UFSAR Section 9.7.2, Paragraph " River Water Pumps and Engine-Driven Fire Pump-Intake Structure" Unit Number:
1 Note:
Personnel who initiate changes to the facility or procedures as described in the UFSAR SHALL also initiate a UFSAR change per NPDAP 7.3.
John J. Maracek Q/)h//M
- 2 4 - (/
Preparer (Print)
@p'per's Sgjnature Date Steve A. Nass
[-7 gw d/5o B Independent Rev. (Print) findeperideint Reviewer's Signature Dafe sm u. %sss n s.,
Lu HnL //0gcJt>
Uu)19 Department Approval (Print)
Department Approval Signature Date OSC Concurrence: Meeting Number BV-OSC-24 4f Date 7-I-9 f INTRODUCTION
- 1. Describe the plant or procedure change (test or experiment) being evaluated and its expected effects below.
NPDAP 8.18, Attach.1, Rev. 5 Page 1 of 10 5059_EWS
.g 10 CFR 50.59 EVALUATION WORKSHEET a
- 2. Also desenbe below why the plant or procedure is being changed.
CHANGE DESCRIPTION:
This change is updating the BVPS-1 UFSAR Section 9.7.2, Paragraph " River Water Pumps and Engine-Driven Fire Pump-intake Structure" to identify the normally open/ closed position of the intake Structure Pump Cubicle doors, and the method for addressing an intemal flooding concem within the intake Structure Pump Cubicles for BVPS-1.
The present BVPS-1 UFSAR indicates that the pump cubicle doors would be left open to address intomal flooding in these cubicles. The proposed change would revise the position of the cubicle doors as follows:
- 1. The security / fire doors at the entrance to the pump cubicles would normally be closed except for ingress / egress to address security, fire, and personnel safety concems.
- 2. The security / fire doors interconnecting the pump cubicles would normally be closed except for ingress / egress to address security, fire, and personnel safety concems.
- 3. The flood piumi doors at the entrance to the pump cubicles would normally be open except for maintenance and testing purposes (until an extemal flooding concem would occur).
- 4. The flood protection doors interconnecting the pump cubicles would normally be closed but the door seals would not be pressurized to support ingress / egress for security, fire, and personnel safety concems except for maintenance and testing purposes (until an extemal flooding concem would occur).
Also, based on BVPS-1 UFSAR Appendix D Section D.2.2," Criteria on Pipe Breaks and Cracks," none of the piping contained in the Intake Structure Pump Cubicles meet the criteria for considering potential pipe cracks (i.e., Criteria: The maximum operating pressure exceeded 275 psig and the maximum operating temperatures equaled or exceeded 200 F), therefore no intomal flooding analysis was required by BVPS-1 for these cubicles. However, since the
_ pump cubicles are shared between Unit 1 and Unit 2, intamal flooding concems have been evaluated.
It is noted that BVPS-2 does address intamal flooding concems in 3 of the 4 cubicles that contain BVPS-2 Service Water Pumps per BV-2 UFSAR Secbon 3.68.1.3.4.2, "Intemal Flooding" and BV-2 Calculabon # 211-N-265, Revision 6, 5/27/87., " Flooding Analysis Outside Containment." Also, NED in EM-116106 response dated 4/6/98 concluded that the analysis performed in 211-N-265, Rev. 6 can apply to the 4th cubicle that does not have a BVPS-2 Service Water Putnp.
in addition, NED in EM-116187 recommended that the interconnecting flood protection doors (between pump cubicles A & B and C & D) should be kept in the normally closed position with their seals depressurized for intamal flooding concems due to the potential for a rubber expansion joint failure in the pump cubicle.
NPDAP 8.18, Attach,1, Rev. 5 Page 2 of 10 5059_EWS
,j 10 CFR 50.59 EVALUATION WORKSHEET (continued)
- 3.
Identify the operating parameters, design parameters, and systems affected by the change.
t.
BVPS-1 Systems affected by these changes include: River Water System, Fire Protection System.
~2.
SVPS-2 Systems affected by these changes include: Service' Water System, Fire Protection System.
1 4.
Identify the credible failure modes associated with the change.
If water from a large pipe break or a rubber expansion joint failure is not allowed to flow out through open doors, intemal flooding in a pump cubicle could rise to a level which could fail the MCCs in the cubicle. However, based on BV-1 UFSAR Appendix D Section D.2.2,
" Criteria on Pipe Breaks and Cracks," none of the piping contained in the intake Structure t
Pump Cubicles meet the criteria for considering potential pipe cracks (i.e., Criteria: The -
maximum operating pressure exceeded 275 psig and the maximum operating temperatures equaled or exceeded 200 F), therefore no flooding analysis is required by BVPS-1 in these cubicles. However, since the pump cubicles are shared between Unit 1 and Unit 2, internal
, flooding concems from either Unit's piping in the pump cubicles have been evaluated.
It is noted that BVPS-2 does address intemal flooding concems in 3 of the 4 cubicles that contain BVPS-2 Service Water Pumps per BV-2 UFSAR Section 3.68.1.3.4.2, "Intemal 1
Flooding" and BV-2 Calculation # 211-N-265, Revson 6, 5/27/87, " Flooding Analysis Outside Containment.". Also, NED in EM-116106 response dated 4/6/98 concluded that the analysis performed in 211-N-265, Rev. 6 can apply to the 4th cubicle that does not have a BVPS-2 Service Water Pump.
In addition, NED in EM-116187 recommended that the interconnecting flood protection doors (between pump cubicles A & B and C & D) should be kept in the normally closed position for intemal flooding concems due to the potential for a rubber expansion joint failure in the pump cubicle.
i l
NPDAP. 8.18, Attach,1, Rev. 5 Page 3 of 10 5059.,,,EWS
10 CFR 50.59 EVALUATION WORKSHEET (continutd) '
- 5. -
Provide references to the location of.information used for the safety evaluation.
1.
BVPS-1 UFSAR Section 9.7.2, Paragraph " River Water Pumps and Engine-Driven Fire
- Pump-Intake Structure" 2.
BVPS-1 UFSAR Appendix D " Report of the Effects of a Piping System Break Outside Containment"(Refer to Sections D.1, " Introduction"; D.2.2, " Criteria on Pipe Breaks and Cracks"; and D.5, " Plant Protection")
3.
BVPS-1 Tech Spec 3/4.7.4, " Reactor Plant River Water System" 4.
BVPS-1 Tech Spec 3/4.7.5, " Ultimate Heat Sink - Ohio River"
.5.
BVPS-1 Tech Spec 3/4.7.6, " Flood Protection" 6.
BVPS-1 AEC Question 3.61 7.
BVPS-1 SER Section 3.4, " Water Level (Flood) Design 8.
BVPS-1 Calculation # 8700-DMC-3438, Resision 0, "BVPS Intake Structure Cubicles Internal Flood Analysis" 9.
BVPS-2 UFSAR Section 3.6B.1.3.2.4, " Environmental Effects"- Internal Floodino
- 10. BVPS-2 UFSAR Section 3.6B.1.3.4.2, " Internal Flooding" 11.' BVPS-2 Calculation # 211-N-265, Revision 6,5/27/87, " Flooding Analysis Outside Containment"
- 12. EM-116106 response dated 4/7/98, " Engineering Support for CR#980472, " Unit 1 UFSAR Discrepancy Concerning the Positions of Intake Structure Cubicle Doors"
- 13. EM-116187 dated 4/7/98, " Additional Engineering Support for CR#980472, " Unit 1 UFSAR Discrepancy Concerning the Positions of Intake Structure Cubicle Doors"
- 14. BVPS-1 Condition Report 980472, " Unit 1 UFSAR Discrepancy Concerning the Positions of Intake Structure Cubicle Doors"
- 15. SER 32-85, " Internal Flooding of Plant Pump House Resulting in Loss of Circulating and Station Service Water for Two Units"
- 16. NDISEG 1025 dated 8/22/96, " Evaluation of Internal Flooding at BVPS"
- 17. BVPS-1 Specification No. BVS-525, " Specification for Heavy Steel Plate Flood Doors" 6.
- Identify specific UFSAR parts (i.e., pages, tables and/or figure numbers) modified or potentially modified by this facility change, procedure change, test or experiment.
l BVPS-1 UFSAR Section 9.7.2, Paragraph
- River Water Pumps and Engine-Driven Fire Pump-Intake Structure *, (see Attachment 1 for present and proposed UFSAR words.)
NPDAP 8.18, Attach.1, Rev. 5 Page 4 of 10 5059_.EWS
e 10 CFR 50.59 EVALUATION WORKSHEET (continued)
PART 1: EFFECT ON DESIGN BASIS (UFSAR) ACCIDENTS 1.A Supporting information 1.A.1 Identify the safety SYSTEMS and/or SYSTEMS important to safety affected by the change.
1.
BVPS-1 safety SYSTEMS and/or SYSTEMS important to safety affected by these changes include: River Water System, Fire Protection System.
2.
BVPS-2 safety SYSTEMS and/or SYSTEMS important to safety affected by these changes include: Service Water System, Fire Protection System.
1.A.2 Discuss the effects of the change and/or the failure modes associated with the change on the probability of failure of the systems identified.
This change is updating the BVPS-1 UFSAR Section 9.7.2, Paragraph " River Water Pumps and Engine-Driven Fire Pump-Intake Structure" to correctly identify the normally open/ closed position of the intake Structure Pump Cubicle doors, and the method for addressing an intamal flooding concem within the intake Structure Pump Cubicles for BVPS-1.
The present BVPS-1 UFSAR indicates that the pump cubicle doors would be left open to
{
address intamal flooding in these cubicles. The proposed change would clarify that the i
" flooding" pump cubicle doors would normally be opened and the Security / Fire pump cubicle doors would normally be closed.
The position of the doors does not affect the normal operation or design of the River Water, Service Water, or Fire Protection Systems.. Whether the doors are open or closed will not 4
affect the reliability of these systems orimpact the probability of failure of those systems.
1.A.3 Discuss the effect of the change on the performance of the safety SYSTEMS.
Since this change recognizes the present condition in the intake Structure Pump Cubicles which was evaluated by BVPS-2 UFSAR Section 3.68.1.3.4.2, "Intemal Flooding," there are no effects on the performance of the safety SYSTEMS that are associated with these changes as previously evaluated in the UFSAR. Also, NED in EM-116106 response dated 4/6/98 concluded that the analyses performed in 211-N-265, Rev. 6 can be applied to the 4th cubicle that does not have a BVPS-2 Service Water Pump.
1.A.4 Identify the design basis accidents in the UPDATED FINAL SAFETY ANALYSIS REPORT (UFSAR) to be reviewed for potential impact by the change.
l-Based on BVPS-1 UFSAR Appendix D Section D.2.2," Criteria on Pipe Breaks and Cracks,"
l none of the piping contained in the intake Structure Pump Cubicles meet the criteria for l
considering potential pipe cr* (i.e., Criteria: The maximum operating pressure exceeded l
l
' 275 psig and the maximum aner. ting temperatures equaled or exceeded 200 F), therefore l
no flooding analysis is requhd) oy BVPS-1 in these cubicles. However, since the pump cubicles are shared between Unit 1 and Unit 2, intomal flooding concems have been evaluated.
I Changing the description of flooding protection for the intake structure pump cubicles does not impact any design basis accident.
4 NPDAP 8.18, Attach.1, Rev. 5 Page 5 of 10 5059_EWS
10 CFR 50.59 EVALUATION WORKSHEET (continued)
PART 1: EFFECT ON DESIGN BASIS (UFSAR) ACCIDENTS 1.A.5 Discuss how the parameters and SYSTEMS, affected by the change, affect the assumptions and radiological consequences of the accident (s) identified in Part 1, A.4 and whether the radiological consequences exceed the values reported in the UFSAR.
There are no changes in any radiological consequences. Changing the description of the flooding protection for the intake structure pump cubicles does not affect radiological consequences.
1.A.6 Identify the design basis accidents, if any, for which failure modes associated with the change can be an initiating event.
Changes to the description of flooding protection for the intake structure pump cubicles do l
not impact or create any new initiating event.
I 1.A.7 Discuss the effect of the change on the probability of occurrence of the design basis l
accidents identified in Part 1, A.6.
There is no change to the probability of occurrence of any design basis accident.
1.
l l
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NPDAP 8.18, Attach.1 Rev. 5 Page 6 of10 5059_EWS
10 CFR 50.59 EVALUATION WORKSHEET (continu:d) i PART 1: EFFECT ON DESIGN BASIS (UFSAR) ACCIDENTS 1.B.
Evaluation Questions 1.B.1 Based on Part 1, A.2, MAY the proposed change increase the probability of occurrence of a i
malfunction of equipment important to safety evaluated previously in the UFSAR?
YES O NO @
1.B.2 Based on Part 1, A.3, MAY the proposed change increase the consequences of a malfunction of equipment important to safety evaluated previously in the UFSAR?
YES O NO E 1.B.3 Based on Part 1 A.5, MAY the proposed change increase the consequences of an accident evaluated previously in the UFSAR7 -
YES O NO E i
1.B.4 Based on Part 1, A.6 and A.7, MAY the proposed change increase the probability of occurrence of an accident evaluated previously in the UFSAR7 YES O NO g IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS IS YES, THE CHANGE REPRESENTS AN UNREVIEWED SAFETY QUESTION.
I l
PART 2: POTENTIAL FOR CREATION OF NEW TYPE OF UNANALYZED EVENT 2.A Supporting Information i
2.A.1 Based on Part 1, assess the impact of the change and/or failure modes associated with the change, to determine if the impact has modified the plant response to the point where it can be considered a new type of accident. Discuss the basis for this determination.
The effect of flooding the pump cubicles was not considered in BVPS-1 because open cubicle access doors would permit excess water to flow out of the cubicles, and pipe cracks in moderate energy piping was not part of the design basis. Revising the door arrangement described in the BVPS-1 UFSAR such that the security / fire doors are normally closed, requires that the effects of flooding be considered. Engineering analysis 8700-DMC-3438, Revision 0 shows that a moderate energy pipe crack, (i.e. the BVPS-2 design basis internal flood), produces a leak rate of 1162 gpm, which result in a maximum water level of 0.82 feet, with the security / fire doors closed. The water level in the adjacent cubicle would reach a level at 0.37 feet. This is below the level which would cause failures of the MCCs in the pump cubicles.
)
The maximum leak rate from a failure at a rubber expansion joint in a pump cubicle would result in water rising to a level which would cause the MCCs to be flooded and fait, thueivie l
maintaining the flood door between the adjacent cubicles closed limits the impact to a single i
train.
\\
Failure of a single train of River Water is analyzed in the UFSAR therefore, this change would not introduce a new type of accident.
I NPDAP 8.18,' Attach.1, Rev. 5 Page 7 of10 5059_EWS ie-_______-__-__-__
10 CFR 50.59 EVALUATION WORKSHEET (continued)
PART 1: EFFECT ON DESIGN BASIS (UFSAR) ACCIDENTS 2.A.2 Determ'ine if the failure modes of equipment important to safety associated with the change represent a new unanalyzed type of malfunction. Discuss the basis for this determination.
Review of the BV-1 UFSAR indicates that intemal flooding was considered based on only high energy piping failures (and moderate energy pipe cracks were not considered). Based on this, BV-1 did not consider intemal flooding inside the Intake Structure Pump Cubicles since there is no high energy piping in this area.
' Based on a review of BV-2's present design bases as discussed in item 2.A.1, the security / fire doors could still be closed and the MCCs in the cubicles would not be affected due to flooding from a moderate energy pipe crack.
Failure of a Unit i rubber expansion joint could affect (flood out) the MCCs in the cubicle, and challenge the integrity of the interconnecting security / fire doors. Because of flooding due to a rubber expansion joint failure, this could create the possibility that an interconnecting door could fail open and allow the second system train to flood out and fail (MCC failure in the adjacent cubicles) which is a malfunction of a differert type then previously evaluated in the UFSAR.
2.8 Evaluation Questions 2.B.1 - Based'on Par't 2, A.1, MAY the proposed activity create the possibility of an accident of a different type than any evaluated previously in the UFSAR?
+
YES O NO E 2.B.2 Based upon Part 2, A.2, MAY the proposed activity create the possibility of a malfunction of equipment important to safety of a different type than any evaluated previously in the UFSAR?
YES E No O IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS IS YES, THE CHANGE REPRESENTS AN UNREVIEWED SAFETY QUESTION.
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NPDAP 8.18, Attach.1, Rev. 5 Page 8 of10 5059_EWS f
3 10 CFR 50.59 EVALUATION WORKSHEET (continusd) 3 i
PART 3: IMPACT ON THE MARGIN OF SAFETY 4
'3.A Supporting information 3.A.1 Identify the acceptance limits which form the licensing basis for the TECHNICAL SPECIFICATIONS (i.e., the accident analysis and other design basis) that could be affected by the change.1 Since all of the changes involve updating the BVPS-1 UFSAR to identify the present condition in the plant in the intake Structure Pump Cubicles, there are no acceptance limits affected by these changes which form the licensing basis for the TECHNICAL SPECIFICATIONS (i.e. the accident analysis and other design basis) that could be affected
.by the change.
Review of BVPS-1 TECHNICAL SPECIFICATIONS 3/4.7.4, " Reactor Plant River Water System," 3/4.7.5, PUltimate Heat Sink - Ohio River," and 3/4.7.6, " Flood Protection" indicated there is no specific limit identified except for initiating flooding protection monitoring.
3.A.2 Discuss the impact of the change on the acceptance limits which form the basis for the
- TECHNICAL SPECIFICATIONS.
Since all of the changes involve updating the BVPS-1 UFSAR to identify the present condition in the plant in the intake Structure Pump Cubicles and there are no acceptance limits affected by these changes which form the licensing basis for the TECHNICAL SPECIFICATIONS (i.e. the accident analysis and other design basis) that could be affected by the change, therefore, there is no impact affected as defined in the basis for any TECHNICAL SPECIFICATION.
3.B Evaluation Questions i
3.B.1 Based on Part 3, A.1 and A.2, does the proposed activity reduce the margin of safety as defined in the basis for any TECHNICAL SPECIFICATION?
YES O NO g i
IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS IS YES, THE CHANGE REPRESENTS AN UNREVIEWED SAFETY QUESTION.
PART 4: 10 CFR 50.59 EVALUATION CONCLUSION Based on the evaluation in Parts 1, 2 and 3 the change:
Does not involve an UNREVIEWED SAFETY QUESTION.
X-Involves an UNREVIEWED SAFETY QUESTION. Contact Safety and Licensing Depaitment before presenting to the Onsite Safety Committee.
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NPDAP 8.18, Attach.1, Rev. 5 Page 9 of10 5059_EWS
10 CFR 50.59 EVALUATION WORKSHEET (continu9d) j PART 5: ENVIRONMENTAL EVALUATION (Applicable to BVPS Unit 2) 5.A
, Supporting information 5.A.1 Identify any significant increase in any adverse environmental impact previously evaluated in
{
the Final Environmental Statement - Operating License stage, environmental impact appraisals, or in any decisions of Atomic Safety and Licensing Board.
N/A for BVPS-1.
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5.A.2 Identify any significant change in effluents or power level.
N/A forBVPS-1.
1 5.A.3 Identify any matters, not previously reviewed and evaluated in the Environmental Protection Plan, Final Environmental Statement - Operating License Stage, or NPDES permit, which 1
MAY have a significant adverse environmental impact.
N/A forBVPS-1.
l 5.A Evaluation Question l
Based upon Part 5, A.1, A.2 and A.3, the change:
l X
Does not involve an UNREVIEWED ENVIRONMENTAL QUESTION.
Involves an UNREVIEWED ENVIRONMENTAL QUESTION. Contact Safety and Licensing Department before presenting to the Onsite Safety Committee.
NPDAP 8.18, Attach.1, Rev. 5 Page 10 of 10 5059.,_EWS
i 10 CFR 50.59 EVALUATION WORKSHEET (continued) c PART 5: ENVIRONMENTAL EVALUATION (Applicable to BVPS Unit 2)
Present and Proposed Words for BVPS-1 UFSAR Section 9.7.2, Paragraph
" River Water Pumps and Engine-Driven Fire ' Pump-Intake Structure"
)
(Attachment 1)
)
Present BVPS-1 UFSAR Words River Water Pumns and Encine-Driven Fire Pumn-Intake Structure There are no equipment or floor drains located in the intake structure. There are no precautions necessary to prevent flooding in the event of a major pipe rupture in any of the pressure water lines in the pump cubicles because open cubicle access doors will permit excess water to flow out of the cubicles. The pump cubicles are structurally protected from ingress of water from the probable maximum flood.
1 Pronosed BVPS-1 UFSAR Words River Water Pumns and Encine-Driven Fire Pumn-Intake Structure l
i Each Intake Structure Pump Cubicle has an emergency-powered sump pump which is controlled by a float switch. The external flood protection doors leading into each Intake Structure Pump Cubicle are normally open with their associated security / fire doors normally closed. The interconnecting flood protection doors that are located between the pump cubicles are normally closed with their seals depressurized, along with their associated security / fire doors normally closed. These door seals will be pressurized in the event of an external flood or for seal testing purposes. This arrangement is designed I
to protect the interconnecting cubicles from the consequences of a major pipe rubber expansionjoint failure.
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i NPDAP 8.18, Attach.1, Rev. 5 Page 11 of 10 5059_EWS L
s s
)
BVPS Intake Structure Pump Cubicle Arrangement l
"A" Cubicle BV-1 Entrance River Water Door
'A' Pump
'~
.N "B" Cubicle BV-1 BV-2 River Water Service Water
'B' Pump
'C' Pump "C" Cubicle BV-1 BV-2 River Water Service Water
'C' Pump sB' Pump N
"D" Cubicle
/
BV-2 Service Water
'A' Pump Flood Door
ATTACHMENT C-2 Beaver Valley Power Station, Unit No. 2 Proposed License Amendment Request No. 128 UFSAR SECTION 3.6.B.1.3.4.2 REVISION Attached is the 10 CFR 50.59 evaluation that documente the unreviewed safety question.
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10 CFR 50.59 EVALUATION WORKSHEET i
Plant Change or Procedure No.
BVPS-2 UFSAR Section 3.68.1.3.4.2 Revision No.
l Plant Change o'r Procedure
Title:
Update BVPS-2 UFSAR Section 3.6B.1.3.4.2, " Internal Flooding"
- Intake Structure" Unit Number: 2 Note:
Personnel who initiate changes to the facility or procedures as described in the UFSAR SHALL also initiate a UFSAR change per NPDAP 7.3.
John J. Maracek RgFJ V)awf.
7[f/@
Preparer (Print)
Ri6(arer's Signature -
Datd Steve A. Nass IW 7
8 Independent Rev. (Print)
/ Indepe6d6nt Reviewer's Signature Date SAM O 14cbk5 [5.f..Mami OMMM $
7-f'48 Department Approval (Print)
Departm6 fit %ppro(al Signstup '""
Date OSC Concurrence: Meeting Number BV-OSC-217
'l8 Date 7-f-T2 INTRODUCTION
- 1. Describe the plant or procedure change (test or experiment) being evaluated and its expected effects below.
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NPDAP 8.18, Attach.1, Rev. 5 Page 1 of g 5059_EWS
10 CFR 50.59 EVALUATION WORKSHEET 4
Plant Change or Procedure No.
BVPS-2 UFSAR Section 3.68.1.3.4.2 Revision No.
O Plant Ch'ange or Procedure
Title:
Update BVPS-2 UFSAR Section 3.68.1.3.4.2, " Internal Flooding"
}
- Intake Structure" Unit Number: 2 Note:
Personnel who initiate changes to the facility or procedures as described in the UFSAR SHALL also initiate a UFSAR change per NPDAP 7.3.
- .hT.i j
John J. Maracek Q) Jdawh 6-LV-9 9 Preparer (Print)
Prepare'r's Si nature ate Steve A. Nass V
4/p p
independent Rev. (Print)
/ Indepqvid6nt Reviewer's Signature Date Asu \\\\ \\\\ esss 4%
),Rhdh-/gb//ft,.,
$'Yt4c/te Department Approval (Print)
Department Approval Signature Date OSC Concurrence: Meeting Number BV-05C _
26
- Tf Date 1-f -it l INTRODUCTION
- 1. Describe the plant or procedure change (test or experiment) being evaluated and its expected effects below.
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NPDAP 8.18, Attach.1, Rev. 5 Page 1 of 9 5059_ EWS i
4 10 CFR 50.59 EVALUATION WORKSHEET
' 2. Also describe below why the plant or procedure is being changed.
l t-CHANGE DESCRIPTION:
This change is updating the BVPS-2 UFSAR Section 3.68.1.3.4.2, " Internal Flooding" -
" Intake Structure" to identify the normally open/ closed position of the intake Structure Pump Cubicle doors, and the method for addressing an internal flooding concern within the intake Structure Pump Cubicles for BVPS-2 to be consistent with BVPS-1.
The 'present BVPS-2 UFSAR addresses internal flooding in these cubicles. The proposed p
change would establish the position of the flood protection doors as follows:
1.
The flood protection doors at the entrance to the pump cubicles would normally be open except for maintenance and testing purposes (until an external flooding concern would occur).
' 2.
The flood protection doors interconnecting the pump cubicles would normally be closed L
but the door seals would not be pressurized to support ingress / egress for security, fire, l
and personnel safety concerns except for maintenance and testing purposes (until an extemal flooding concem would occur).
L BVPS-2 does address internal flooding concerns for areas that contain BVPS-2 Service Water Pumps per BV-2 UFSAR Section 3.68.1.3.4.2, " Internal Flooding" " Intake Structure" and BV-2 Calculation # 211-N-265, Revision 6,5/27/87, " Flooding Analysis Outside Containment."
In addition, NED in EM-116187 recommended that the interconnecting flood protection doors '
- (between pump cubicles A & B and C & D) should be kept in the normally closed position for internal flooding concems due to the potential for an expansion joint failure in the pump cubicle.
Based on BVPS-1 UFSAR Appendix D Section D.2.2, " Criteria on Pipe Breaks and Cracks,"
none of the piping contained in the intake Structure Pump Cubicles meet the criteria for L
considering potential pipe cracks (i.e., Criteria: The maximum operating pressure exceeded 275 psig and the maximum operating temperatures equaled or exceeded 200 F), therefore no intemal flooding analysis was required by BVPS 1 for these cubicles. However, since the pump cubicles are shared between Unit 1 and Unit 2, intemal flooding concems have been evaluated, l
Also, there is an editorial error in the present BV-2 UFSAR Section 3.68.1.3.4.2, "Intemal Flooding" " Intake Structure" in which (1) statements that are duplicated should be deleted, and -
'(2) words should be added for clarity as identified in Attachment 1.
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l NPDAP 8.18, Attach,1. Rev. 5 Page 2 of 9 5059_EWS
10 CFR 50.59 EVALUATION WORKSHEET (continued) 3.
Identify the operating parameters, design parameters, and systems affected by the change.
1.
BVPS-1 Systems affected by these changes include: River Water System, Fire Protection l_
System.
- 2. ^ BVPS-2 Systems affected by these changes include: Service Water System, Fire Protection System.
4.
Identify the credible failure modes associated with the change.
l The original concern identified in this UFSAR section was potential internal flooding. BVPS-2 addresses intemal flooding concems for areas that contain BVPS-2 Service Water Pumps per BV-2 UFSAR Section 3.68.1.3.4.2, " Internal Flooding" " Intake Structure" and BV-2 Calculation # 211-N-265, Revision 6,5/27/87, " Flooding Analysis Outside Containment."
In addition, NED in EM-116187 recommended that the interconnecting flood protection doors (between pump cubicles A & B and C & D) should be kept in the normally closed position for l
internal flooding concerns due to the potential for an expansion joint failure in the pump cubicle.
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l NPDAP 8.18, Attach.1, Rev. 5 Page 3 of 9 5059_EWS
10 CFR 50.59 EVALUATION WORKSHEET (continued) 5.
Provide references to the location of information used for the safety evaluation.
1.
BVPS-2 UFSAR Section 3.68.1.3.2.4, " Environmental Effects" "Intemal Flooding" 2.
BVPS-2 UFSAR Section 3.68.1.3.4.2, " Internal Flooding" " Intake Structure" 3.
BVPS-2 Tech Spec 3/4.7.4, " Service Water System" 4.
BVPS-2 Tech Spec 3/4.7.5, " Ultimate Heat Sink - Ohio River"
~
5.
BVPS-2 Tech Spec 3/4.7.6, " Flood Protection" 6.
BVPS-2 Calculation # 211-N-265, Revision 6, 5/27/87, " Flooding Analysis Outside 1
Containment" 7.
BVPS-1 UFSAR Appendix D " Report of the Effects of a Piping System Break Outside Containment" (Refer to Sections D.1, " Introduction"; D.2.2, " Criteria on Pipe Breaks and Cracks"; and D.5, " Plant Protection")
8.
EM-116106 response dated 4/7/98, " Engineering Support for CR#980472, " Unit 1 UFSAR Discrepancy Conceming the Positions of Intake Structure Cubicle Doors" 9.
EM-116187 dated 4/7/98, " Additional Engineering Support for CR#980472, " Unit 1 UFSAR Discrepancy Conceming the Positions of Intake Structure Cubicle Doors"
- 10. BVPS-1 Condition Report 980472," Unit 1 UFSAR Discrepancy Concerning the Positions of Intake Structure Cubicle Doors'
- 11. SER 32-85,"Intemal Flooding of Plant Pump House Resulting in Loss of Circulating and Station Service Water for Two Units"
- 12. NDISEG 1025 dated 8/22/96, " Evaluation of internal Flooding at BVPS"
- 13. BVPS-1 Specification No. BVS-525, " Specification for Heavy Steel Plate Flood Doors" 6.
Identify specific UFSAR parts (i.e., pages, tables and/or figure numbers) modified or potentially modified by this facility change, procedure change, test or experiment.
BVPS-2 UFSAR Section 3.68.1.3.4.2, " Internal Flooding" " Intake Structure" (see for present and proposed UFSAR words.)
NPDAP 8.18, Attach.1, Rev. 5 Page 4 of 9 5059_EWS I
10 CFR 50.59 EVALUATION WORKSHEET (continued)
PART 1: EFFECT ON DESIGN BASIS (UFSAR) ACCIDENTS 1.A Supporting information 1.A.1 Identify the safety SYSTEMS and/or SYSTEMS important to safety affected by the change.
1.
BVPS-1 safety SYSTEMS and/or SYSTEMS important to safety affected by these changes include: River Water System, Fire Protection System.
2.
BVPS-2 safety SYSTEMS and/or SYSTEMS important to safety affected by these i
changes include: Service Water System, Fire Protection System.
1.A.2 Discuss the effects of the change and/or the failure modes associated with the change on the probability of failure of the systems identified.
This change is updating the BVPS-2 UFSAR Section 3.68.1.3.4.2, " Internal Flooding" -
" Intake Structure" to identify the normally open/ closed position of the intake Structure Pump Cubicle doors, and the method for addressing an internal flooding concern within the intake Structure Pump Cubicles for BVPS-2 to be consistent with BVPS-1.
The proposed change would establish the position of the flood protection doors as follows:
1.
The flood protection doors at the entrance to thee pump cubicles would normally be open (until an external flooding concern would occur).
2.
The flood protection doors interconnecting the pump cubicles would normally be closed but the door seals would not be pressurized to support ingress / egress to address security, fire, and personnel safety concerns (until an external flooding concern would occur).
1.A.3 Discuss the effect of the change on the performance of the safety SYSTEMS.
Since this change recognizes the present condition in the intake Structure Pump Cubicles which was evaluated by BVPS-2 UFSAR Section 3.68.1.3.4.2, " Internal Flooding" " Intake Structure", there are no effects on the performance of the safety SYSTEMS that are associated with these changes as previously evaluated in the UFSAR.
1.A.4 Identify the design basis accidents in the UPDATED FINAL SAFETY ANALYSIS REPORT (UFSAR) to be reviewed for potential impact by the change.
Changing the description of flooding protection for the intake structure pump cubicles does not impact any design basis accident.
1 NPDAP 8.18, Attach.1, Rev. 5 Page 5 of 9 5059_ EWS
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10 CFR 50.59 EVALUATION WORKSHEET (continued) f PART 1: EFFECT ON DESIGN BASIS (UFSAR) ACCIDENTS (continued)
I 1.A.5 Discuss how the parameters and SYSTEMS, affected by the change, affect the assumptions and radiological consequences of the accident (s) identified in Part 1, A.4 and whether the
(
radiological consequences exceed the values reported in the UFSAR.
There are no changes in any radiological consequences. Changing the description of the flooding protection for the intake structure pump cubicles does not affect radiological consequences.
1.A.6 Identify the design basis accidents, if any, for which failure modes associated with the change can be an initiating event.
Changes to the description of flooding protection for the intake structure pump cubicles do not impact or create any new initiating event.
1.A.7 Discuss the effect of the change on the probability of occurrence of the design basis accidents identified in Part 1 A.6.
There is no change to the probability of occurrence of any design basis accident.
- 1. B.
Evaluation Questions 1.B.1 Based on Part 1, A.2, MAY the proposed change increase the probability of occurrence of a malfunction of equipment important to safety evaluated previously in the UFSAR?
YES U No 0 1.B.2 Based on Part 1, A.3, MAY the proposed change increase the consequences of a malfunction of equipment important to safety evaluated previously in the UFSAR?
YES O No 0 1.B.3 Based on P.irt 1, A.5, MAY the proposed change increase the consequences of an accident evaluated previously in the UFSAR?
YES O No g NPDAP 8.18, Attach.1, Rev. 5 Page 6 of 9 5059_EWS 1
3.
7,.
10 CFR 50.59 EVALUATION WORKSHEET (continued)
PART 1: EFFECT ON DESIGN BASIS (UFSAR) ACCIDENTS (continued) 1.B.4
. Based on Part 1, A.6 and A.7, mat the proposed change increase the probability of occurrence of an accident evaluated previously in the UFSAR?
YES O
- O g IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS IS YES,'
l THE CHANGE REPRESENTS AN UNREVIEWED SAFETY QUESTION.
PART 2: POTENTIAL FOR CREATION OF NEW TYPE OF UNANALYZED EVENT 2.A Supporting information 2.A.1 Based on Part 1, assess the impact of the change and/or failure modes associated with the change, to determine if the impact has modified the plant response to the point where it can be considered a new type of accident. Discuss the basis for this determination.
' Since all of the changes involve updating the BVPS-2 UFSAR to identify the present condition of the plant in the intake Structure Pump Cubicles, there is no plant modification made by these changes to the UFSAR that could impact the plant response to the point where it can be considered a new type of accident as evaluated previously in the UFSAR.'
2.A.2 Determine if the failure modes of equipment important to safety associated with the change represent a new unanalyzed type of malfunction. Discuss the basis for this determination.
Failure of a Unit i rubber expansion joint could affect (flood out) the MCCs in the cubicle, and challenge the integrity of the interconnecting security / fire doors. Because of flooding due to a rubber expansion joint failure, this could create the possibility that an interconnecting door could fail open and allow the second system train to flood e.:t and fail (MCC failure in the adjacent cubicles) which is a malfunction of a different type then previously evaluated in the UFSAR.
2.B '
. Evaluation Questions 2.B.1 Based on Part 2, A.1, MAY the proposed activity create the possibility of an accident of a different type than any evaluated previously in the UFSAR?
YES O NO E 2.B.2 Based upon Part 2, A.2, MAY the proposed activity create the possibility of a malfunction of equipment important to safety of a different type than any evaluated previously in the UFSAR?
YES E NO O IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS IS YES, THE CHANGE REPRESENTS AN UNREVIEWED SAFETY QUESTION.
NPDAP 8.18, Attach.1, Rev. 5 Page 7 of 9 5059_EWS
______.._.._________..________a
[.
10 CFR 50.59 EVALUATION WORKSHEET (continued)
+
PART 3: IMPACT ON THE MARGIN OF SAFETY 3.A
. Supporting information 3.A.1 Identify the acceptance limits which form the licensing basis for the TECHNICAL l
SPECIFICATIONS (i.e., the accident analysis and other design basis) that could be affected -
l by the change.
i Since all of the changes involve updating the BVPS-2 UFSAR to identify the present~
condition of the plant in the intake Structure Pump Cubicles, there are no acceptance limits affected by these changes which form the licensing basis for the TECHNICAL SPECIFICATIONS (i.e. the accident analysis and other design basis) that could be affected by the change.
Review of BVPS-2 TECHNICAL SPECIFICATIONS 3/4.7.4, " Service Water System,"
3/4.7.5, " Ultimate Heat Sink - Ohio River," and 3/4.7.6, " Flood Protection" indicated there is no specific limit identified except for initiating flooding protection monitoring.
J 3.A.2 Discuss the impact of the change on the acceptance limits which form the basis for the TECHNICAL SPECIFICATIONS.
Since all of the changes involve updating the BVPS-2 UFSAR to identify the present condition of the plant in the intake Structure Pump Cubicles and there are no acceptance limits affected by these changes which form the licensing basis for the TECHNICAL SPECIFICATIONS (i.e. the accident analysis and other design basis) that could be affected by the change, therefore, there is no impact affected as defined in the basis for any TECHNICAL SPECIFICATION.
3.8 Evaluation Questions 3.B.1 Based on Part 3, A.1 and A.2, does the proposed activity reduce the margin of safety as defined in the basis for any TECHNICAL SPECIFICATION?
YES O NO E IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS IS YES, THE CHANGE REPRESENTS AN UNREVIEWED SAFETY QUESTION.
PART 4: 10 CFR 50.59 EVALUATION CONCLUSION Based on the evaluation in Parts 1,2 and 3 the change:
Does not involve an UNREVIEWED SAFETY QUESTION.
X Involves an UNREVIEWED SAFETY QUESTION. Contact Safety and Licensing Department before presenting to the Onsite Safety Committee.
NPDAP 8.18, Attach.1, Rev. 5 Page 8 of 9 5059_EWS
\\
10 CFR. $3 EVALUATION WORKSHEET (continu:d)
PART 5: ENVIRONMENTAL EVALUATION (Applicable to BVPS Unit 2) 5.A Supporting Information 5.A.1 Identify any significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement - Operating License stage, environ' mental impact l
appraisals, or in any decisions of Atomic Safety and Licensing Board.
The positioning of the intake Structure Pump Cubicle doors does not effect any environmentalreleases.
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l 5.A.2 Identify any significant change in effluents or power level.
The positioning of the Intake Structure Pump Cubicle doors does not effect effluents or powerlevels.
I 5.A.3 Identify any matters, not previously reviewed and evaluated in the Environmental Protection Plan, Final Environmental Statement - Operating License Stage, or NPDES permit, which MAY have a significant adverse environmental impact.
The Environmental Protection Plan, Final Environmental Statement - Operating License Stage, or NPDES permit, which MA Y have a significant adverse environmentalimpact is not effected by the positioning of the intake Structure Pump Cubicle doors 5.A Evaluation Question Based upon Part 5, A.1, A.2 and A.3, the change:
X Does not involve an UNREVIEWED ENVIRONMENTAL QUESTION.
Involves an UNREVIEWED ENVIRONMENTAL QUESTION. Contact Safety and Licensing Department before presenting to the Onsite Safety Committee.
(
- NPDAP 8.18, Attach.1, Rev. 5 Page 9 of 9 5059_EWS a
1 p.-
Prcacnt cnd Proprod Worda for BVPS-2 UFSAR S0ction
- 3.68.1.3.4.2. " Internal Flooding"
" Intake Structure" l
(Attachment 1) l Present BVPS-2 UFSAR Words 1
i Intake Structure l
The intake structure is shared between Beaver Valley Power Station - Unit 1 (BVPS-1) and i
Beaver Valley Power Station - Unit 2 (BVPS-2). It has four separate cubicles, three of which contain one of the BVPS-2 sewice water pumps. The pump motors and all piping are located above the operating deck in each cubicle, which is Icapable of beinal sealed to protect against external floods.
1 The postulated piping failure, which causes the highest flood level above the operating deck, is a moderate energy crack in a 30-inch service water line. The service water pump motor in the affected cubicle would then be inoperable. However, three service water pumps are provided (Section 9.2). One service water pump is sufficient for emergency shutdown and loss of one pump during normal operation does not require immediate plant shutdown. The Technical Specifications (Chapter 16) gove.'n the length of time BVPS-2 can operate with one of the redundant service water flow paths out of service. The length of time allowed is sufficient for the operator to align the third (spare) service water pump electrically and hydraulically to the flow path of the inoperable pump. As discussed in Section 3.68.1.3.1, Single Failure Application, single failure of the operating service water pump need not be assumed following a piping failure, since the service water system (SWS) (moderate energy) is designed to QA Category I and Seismic Category I standards and the pumps are powered from water numa need not be assumed followina a oloina failure. since the service water svstem (SWS) (moderate enerav) is deslaned to QA Cateaorv i and Seismic Cateaorv I standards and the numos are cowered from the Class 1E buses. Therefore, lose of one pump due to flooding has no adverse safety considerations.
Proposed BVPS-2 UFSAR Words (Add the following words to the bottom of the above section)
Since the intake Structure pump cubicles are shared between'BVPS-1 and BVPS-2, internal flooding concerns have been evaluated. The external flood protection doors leading into each Intake Structure Pump Cubicle are normally open with their associated security / fire doors normally closed. The interconnecting flood protection doors that are located between the pump cubicles are normally closed with their seals depressurized, along with their I
associated security / fire doors normally closed. These door seals will be pressurized in the event of an external flood or for seal testing purposes. This arrangement is designed to l
protect the interconnecting cubicles from the consequences of a major pipe rubber l
expansion joint failure.
l Note:
For editorial corrections in the present BVPS-2 UFSAR words, 1.
delete the underlined, bolded, italicized words, and 2.
add the underlined bolded bracketed words.
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BVPS Intake Structure Pump Cubicle Arrangement l
I' "A" Cubicle BV-1 Entrance l
River Water
'A' Pump
- Door
.N "B" Cubicle BV-1 BV-2 River Water Service Water
'B' Pump
'C' Pump "C" Cubicle
~
BV-1 BV-2 River Water Service Water
' 'C' Pump
'B' Pump
.N "D" Cubicle
/
BV-2 Service Water
'A' Pump Flood Door i
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