ML20249C316
| ML20249C316 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/19/1998 |
| From: | DUQUESNE LIGHT CO. |
| To: | |
| Shared Package | |
| ML20249C315 | List: |
| References | |
| NUDOCS 9806290045 | |
| Download: ML20249C316 (9) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _
l .
ATTACHMENT A-1 Beaver Valley Power Station, Unit No. 1 Proposed License Amendment Request No. 256 l
l I The following is a list of the affected page:
i Affected Page: 1-2 9
f l
9806290045 900619 PDR ADOCK 05000334 p PM
l DPR-66
' DEFINITIONS REPORTABLE EVENT ;
1.7 A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 to 10 CFR Part 50.
CONTAINMENT INTEGRITY 1.8 CONTAINMENT INTEGRITY shall exist when:
1.8.1 All penetrations required to be closed during accident conditions are either:
- a. Capable of being closed by an OPERABLE containment automatic isolation valve system, or
- b. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are open 4 under administrative control as permitted by I Specification 3.6.3.1.
1.8.2 All equipment hatches are closed and sealed,
. 1.8.3 Each air lock is in compliance with the requirements of Specification 3.6.1.3, 1.8.4 The containment leakage rates are within the limits of Specification 3.6.1.2, and 1.8.5 The sealing mechanism associated with each penetration (e.g., welds, bellows, or 0-rings) is OPERABLE.
CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with.the necessary range and accuracy to known values ' of the parameter which the channel I monitors. The CHANNEL CALIBRATION shall encompass the entire channel i including the sensor and alarm and/cr trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument l channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or total channel steps such that the entire channel is calibrated.
CHANNEL CHECK 1.10 'A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indications and/or status derived from independent instrument channels measuring the same parameter.
l l BEAVER VALLEY - UNIT 1 1-2 Amendment No.
l (Proposed Wording)
l n
, ATTACHMENT A-2 Beaver Valley Power Station, Unit No. 2 Proposed License Amendment Request No. 126 The following is a list of the affected page:
Affected Page: 1-2 l
l 1
' DEFINITIONS )
CONTAINMENT INTEGRITY (Continued)
- b. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except for valves that are open under administrative control as permitted by Specification 3.6.3.1.
1.8.2 All equipment hatches are closed and sealed, 1.8.3 Each air lock is in compliance with the requirements of Specification 3.6.1.3, l 1.8.4 The containment leakage rates are within the limits of Specification 3.6.1.2, and 1.8.5 The sealing mechanism associated with each penetration (e.g., welds, bellows, 0-rings) is OPERABLE.
CHANNEL CALIBRATION 1.9 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel moni, tors. The CHANNEL CALIBRATION shall encompass the ' entire channel, including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross ;
calibration that compares the other sensing elements with the )
recently installed sensing element. The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.
CHAENEL CHECK J 1.10 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or i status with other indications and/or status derived from independent instrument channels measuring the same parameter.
CHANNEL FUNCTIONAL TEST 1.11 A CHANNEL FUNCTIONAL TEST shall be the injection of a simulated signal into the channel as close to the primary sensor as practicable to verify OPERABILITY, including alarm and/or trip functions.
CORE ALTERATION 1.12 CORE ALTERATION shall be the movement or manipulation of any component within the reactor pressure vessel with the vessel head removed and fuel in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe, conservative position.
BEAVER VALLEY - UNIT 2 1-2 Amendment No.
(Proposed Wording)
~
ATTACIU4ENT B I
Beaver Valley Power Station, Unit Nos. 1 and 2 Proposed License Amendment Request Nos. 256 and 126 REVISION OF DEFINITION OF CHANNEL CALIBRATION A. DESCRIPTION OF AMENDMENT REQUEST i The proposed amendment would revise the existing definition of Channel Calibration in~ Technical Specification 1.9 to add the l following two sentences. " Calibration of instrument channels with l
resistance temperature detector (RTD) or thermocouple sensors may l consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required Channel Calibration shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element." l B. DESIGN BASES ,
1 l Resistance Temperature Detectors [RTDs) and thermocouple are I
used in various circuits at Beaver Valley. These sensors are used in the Overtemperature AT, Overpower AT, the Engineered Safety
- Features [ESF] P-12 interlock, the Meteorological Tower AT, I
remote shutdown panel, Reactor Coolant System [RCS) hot and cold leg temperatures, RHR heat exchanger outlet temperature, RCS subcooling margin indication, in-core temperature indication, i l Reactor Vessel Level Indication System temperature compensation, l
and hydrogen recombiner heater outlet temperature instrumentation systems. The surveillance of these instrumentation systems are l
specified in Technical Specification Tables 4.3-1, 2, 5, 6, & 7.
- These tables require Channel Calibration for each of these l instruments.
C. JUSTIFICATION The present definition of Channel Calibration requires that Channel Calibration shall encompass the entire channel,
- including the sensor, and shall include the Channel Functional Test. RTDs and thermocouple are not adjustable during calibration and in the case of in-core thermocouple are not i
accessible without significant exposure to ionizing radiacion.
l The Standard Technical Specifications, as described in NUREG 1431 l provides a definition of Channel Calibration that permits the use of a qualitative assessment of RTD or thermocouple behavior in lieu of normal calibrations. The inplace cross calibration of RTDs and thermocouple is an acceptable method of performing a qualitative assessment of these sensors' behavior as delineated in NRC Branch Technical Position HICD-13, " Guidance on Cross Calibration of Protection System Resistance Temperature Detectors," Rev. 4, June 1997. Acceptance of cross calibration of RTDs and thermocouple by averaging all sensors measuring the same variable and comparing each individual sensor with the average has been approved by the NRC in the past. This has l
l
I
~
~ ATTACHMENT B,.c:ntinu d PrcpOcd LicCnco Am:ndO:nt Request Nos. 256 and 126 Page 2 occurred in the case of license amendments which have adopted the Standard' Technical Specification [STS] definition of Channel Calibration for Units 1 and 2 at Salem (Amendments 191 and 174),
Susquehanna (Amendments 133 and 102) and La Salle (Amendments 120 and 105), as-recently as September 1997.
D. SAFETY ANALYSIS
, This proposed revision to the Beaver Valley Unit 1 and 2 Technical' Specifications is being requested to better account for -
standard industry methodology for temperature sensor Channel l Calibration. This methodology avoids unnecessary removal or l replacement of these sensors from their installed location for- I calibration. Removal and installation.of RTDs or thermocouple solely for the purpose of calibration could introduce errors, {
cause sensor damage, and increase personnel exposure to ionizing radiation. Most of these sensors are located in systems containing radioactive fluid.
In order.to confirm the calibration of instrument channels having RTDs or thermocouple temperature sensors Duquesne Light Company
[DLC] will be performing inplace qualitative assessments of sensor behavior. The RCS loop RTDs are cross calibrated in accordance with current procedures. The other required Technical Specification RTD and thermocouple qualitative assessments will be completed prior to changing modes from the . present plant operating Mode, which is Mode 5, cold shutdown. Subsequent RTD and -thermocouple qualitative assessments will be performed consistent with the frequency specified in the current. Technical Specifications. If calibration of a temperature sensor is confirmed by inplace qualitative assessment using cross calibration, and if that temperature sensor must be replaced, the next required. Channel Calibration will include an inplace cross calibration which compares the similarly located sensing elements with the recently installed sensing element.
The issue of cross calibration was addressed in NUREG/CR-5560,
" Aging of Nuclear Plant Resistance Temperature Detectors," which recognizes that on-line cross calibration can be a reasonable method for temperature detector calibration. However, as stated in NUREG/CR-5560, to perform in-situ calibration would normally
. require one or more newly calibrated sensors to be used as a reference. Without a reference, the cross calibration might not account for common cause drift. The cross calibration technique assumes that the average of the sensor measurements represents the true process temperature and that sensor drift is random and not systematic. The results of studies referenced in NUREG/CR-5560 indicated that sensor drift is random in nature.
Therefore, the cross calibration technique is an acceptable method of performing the qualitative assessment of temperature sensor behavior discussed in the attached proposed change to the Beaver Valley Unit 1 and 2 Technical Specification, Section 1.9, Channel Calibration definition.
l B-2
.., i j
~
- ATTACHMENT B, continu2d i Propoacd Lic:nco AmsndatntRiquost nod. 256 and 126 l
- Page:3 In the NRC ' letter from Donald Brinkman to DLC [J. E. Cross) of June 11,-1998,~ the.NRC stated that ". . . Adoption of improved STS surveillance- requirements- (SR) for 'RTDs and' thermocouple L includes. additional' testing requirements specified in the SR notes such as verifying rate lag compensation for flow from the core to:the RTDs." In a telephone call between a member of the DLC staff and a member of the NRC Technical Specification Branch on June 16,:1998, it was stated that. this provision of the. NRC June.11' letter referred to the STS Bases,. assuming the RTDs are in- an RCS bypass loop. The STS Bases for SR : 3. 3.1.12 states, "This. test will verify the rate lag compensation for flow from the core to the RTDs." In view of the fact that neither unit at the Beaver Valley Station has a bypass loop for the . RCS RTDs, they are in thermal wells directly immersed in the main RCS loop, no additional ~ response to the above quoted statement in the June 11 NRC letter is being provided.
The modifled-' channel Calibration definition is functionally consistent with . the Improved Standard Technical Specifications (ISTS), provides. clarification of the channel Calibration requirements- and ' maintains compliance with -the -applicable I specification operability requirements. This change does not I affect the' system description or .UFSAR accident analyses; therefore, this change-- has been determined to be safe and will i not-reduce:the safety of the. plant.
E. NO SIGNIFICANT HAZARDS EVALUATION' _
e ..The ' no' significant hazard considerations involved' with the )
proposed amendment have been evaluated, focusing on the three standards set forth in 10 CFR 50.92(c) as quoted below:
The ' Commission may make.' a final ~ determination, pursuant to the procedures'in paragraph 50.91, that a proposed amendment 4 toL an- operating. license ;for 'a facility licensed _ under !
paragraph '50.21(b) 'or paragraph 50.22 or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed j' amendment would not:'
E (1) Involve a significant increase in the probability or j -
consequences of.an accident previously evaluated; or (2) Create the possibility of a new or different kind of 1 accident from.any accident previously evaluated; or ,
i i
(3) Involve.a significant reduction in a margin of safety.
The .following evaluation 'is provided for the no significant l
' hazards consideration standards, i l
B-3 7
'
- ATTACHMENT ~ B, ccntinutd 3 Proposed Licznso Am:ndssnt R2quont Nos. 256 and 126 i Page:4~ !
- 1. - Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change is administrative in nature. It does not involve any change to the configuration or method - of operation of any plant equipment that is used to mitigate the consequences of an accident nor alter the conditions or ]
assumptions in any . of the Updated Final Safety -Analysis '
Report (UFSAR) ' accident analyses. The revised definition would elimir. ate unnecessary- and potentially damaging removal of resistance temperature detector .(RTD) or thermocouple sensors in order- to perform calibrations that are not technically possible. Therefore, it can be concluded that the proposed changes do not involve any increase in the l probability or consequences of an accident previously 'l evaluated. j i
- 2. Does1the change create the possibility of a new or different I kind of accident from any accident previously evaluated?
/
~
No new failure modes have been defined for any plant system or component; important to safety nor _ has any new limiting failure been identified as a result of the proposed changes.
There will be no change in the requirement to'- assess - the entire RTD or thermocouple channel behavior including the L
-sensor, alarm, display, and/or trip function.- Therefore, it
'can.be. concluded that the proposed change does not' create the possibility of a new or difforent kindLof accident from those
'previously evaluated.
- 3. Does'the change involvea significant reduction in a margin of safety?
The proposed change is administrative in nature. Assessment )
of channel behavior, including sensors, will continue to be !
required. The addition to'the channel-' Calibration definition i l < 'will provide greater flexibility in the use of the' provision j for surveillance-testing, and will have no' adverse effect on ;
- - safety. Also, the inplace qualitative assessment obviates !
the' need to remov2 the RTDs or ' thermocouple- from their ,
installed location, thereby eliminating the possibility of i damaging.them during removal. Therefore, it can'be concluded ;
that the proposed changes do not involve any reduction'in a
-margin of safety. ;
IF. NO SIGNIFICANT. HAZARDS CONSIDERATION DETERMINATION j Based on'the considerations expressed above, it is concluded that ,
the -activities associated ' with this license amendment request j satisfy-the requirements of 10 CFR 50.92 (c) and, accordingly, a i no-significant hazards consideration finding is justified.
l I
B-4
- ATTACHMENT B, cantinutd Prop 2 cod License Amendment Request Nos. 256 and 126 Page.5 ;
G. ENVIRONMENTAL CONSIDERATION !
This license amendment request changes a requirement with respect to the installation or use of a facility component located within the restricted area- as defined in 10 CFR Part 20. 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 i 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 surveillance requirement; however, the category of this licensing action does not individually or cumulatively have a significant effect on the human environment. Accordingly, ;
this license amendment request meets the eligibility criteria for l categorical exclusion . set forth in 10 CFR 51.22 (c) (9) . Pursuant i to 10 CFR 51.22(b) no environmental impact statement or j environmental assessment need be prepared'in connection with the '
. issuance of this license amendment request. .I
.I
-H. UFSAR CHANGES No UFSAR changes are required. l
, 1 4
B-5 L.