ML20248A626

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Proposed Tech Specs Removing Containment Isolation Valve SI-91 from Table 3.6-1
ML20248A626
Person / Time
Site: Beaver Valley
Issue date: 09/22/1989
From:
DUQUESNE LIGHT CO.
To:
Shared Package
ML20248A617 List:
References
NUDOCS 8910020266
Download: ML20248A626 (5)


Text

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ATTACHMENT A i

Revise the Technical Specifications as follows:

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ATTACHMENT B I

Safety Analysis l

Beaver Valley Power Station, Unit No. 1 Proposed Technical Specification Chance No. 170 Description of Amendment Request:

The proposed amendment would revise Table 3.6-1, Containment Penetrations, to remove containment i

isolation valve SI-91 listed for penetration 113-1-A.

SI-91 is installed in a 1" line that bypasses the Boron Injection Tank (BIT).

Prior to Technical Specification (TS)

Amendment 71 the BIT was maintained at a

boron concentration of 20,000 ppm.

The safety injection piping downstream of the BIT isolation valves is not heat traced or insulated, therefore, the 1" BIT bypass piping via SI-91 was used to flush this' downstream piping after a safety injection actuation or a functional test.

This was done to ensure the residual boron concentration downstream of the BIT was sufficiently diluted to preclude boron precipitation and avert clogging the pipe.

TS Amendment 71 reduced the required BIT boron concentration so that flushing the downstream piping is no longer required.

Also, this piping configuration is similar to that identified in NRC Bulletin No.

88-08

" Thermal Stresses in Piping Connected to Reactor Coolant Systems",

if this valve and piping were removed the potential for the incident that occurred at Farley Unit 2 would be eliminated.

Removal of this valve from the TS would allow cutting the piping and welding caps on the ends of the pipe stubs that will remain attached to the safety injection piping.

This will remove the major portion of the BIT bypass piping and eliminate SI-91 as a containment isolation valve.

This will reduce the preparation and testing time since this valve will no longer be Type C tested.

ALARA dose savings will also be involved and include a

corresponding reduction in exposure proportional to the Type C testing man-hours that will be eliminated in addition to that no longer required for operations valve lineup and verification.

UFSAR changes to Section 5.3.3.1, Tables 5.3-1 and 5.3-1A and Figure 6.3-1 will be incorporated to reflect the removal of SI-91 and applicable piping following implementation of this design change.

The proposed change will allow cutting and capping the BIT bypass piping since this piping and associated containment isolation valve are no longer required to perform the original design function of flushing the safety injection piping downstream of the BIT after a safety injection actuation or functional test.

The pipe caps installed on the pipe stubs attached to the safety injection piping will be welded in place and will be subject to examination and test.

Therefore, the caps will provide the required isolation capability and will not affect the accident analysis or reduce the safety of the plant.

ATTACHMENT C r.

No Significant Hazard Evaluation Beaver Valley Power Station, Unit 1 Proposed Technical Specification Chance No. 170 Basis for proposed no significant hazards consideration determination:

The Commission has provided standards for determining whether a

significant hazards consideration exits in accordance with 10 CFR 50.92(c).

A proposed amendment tc an operating license for a

facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the 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.

The proposed changes do not involve a

significant hazard consideration because:

1.

A plant design change is proposed to cut and cap the 1 inch Boron Injection Tank (BIT) bypass piping.

The caps will be seal welded to ensure a

leak tight containment isolation boundary.

This results in the elimination of containment isolation valve SI-91 listed for penetration 113-1-A in Technical Specification (TS) Table 3.6-1.

This piping and associated containment isolation valve were originally installed to flush the safety injection piping downstream of the BIT after a safety injection actuation or functional test.

TS Amendment 71 reduced the required BIT boron concentration so that flushing the downstream piping is no longer required.

In

addition, this piping configuration is similar to that arrangement identified in NRC Bulletin 88-08 " Thermal Stresses in Piping Connected to Reactor Coolant Systems" and if this valve and piping were removed the potential for the incident that occurred at Farley Unit 2 would also be removed.

This would effectively increase the safety posture of the plant by eliminating a potential unisolable piping failure.

Removal of this valve and piping would reduce the radiation exposure received by plant personnel, in keeping with the ALARA program, since this valve will be removed from the Type C testing program.

Dose received by the plant operations will also be reduced since they will no longer perform valve lineup and verification on these valves.

1Attachm:nt C (Continusd)

The. proposed ' change will allov' cutting and capping the.1

' inch BIT _ bypass piping and eliminate containment isolation

(

valve' SI-91.

This valve and piping are no longer required L

and the caps will be seal welded to ensure containment and safety. injection system integrity are maintained, therefore, 1the. probability or consequences -of an accident previously

' evaluated will not be significantly increased.

2.

The. containment isolation' valve will be physically. removed and will no longer provide

  • a potential -pathway for containment leakage.

The seal welded caps on the' piping will eliminate the potential for containment and safety injection leakage through this piping.

Therefore, the proposed change will not create the possibility of a new or different kind of accident from any ' accident previously evaluated.

3.

The leak tight integrity of the containment boundary will be maintained by the-seal welded caps which replace the containment isolation valve for this penetration.

The original function of this BIT bypass. piping. has. been-

. superceded, consequently, thin valve and piping is no. longer required.

.Therefore, the proposed changes will not involve a

significant reduction in the margin of safety of the plant.

Therefore, based on the above. considerations, this amendment does not involve a significant hazard.

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