ML20005E215

Proposed Tech Specs Revising Page 3/4 5-2 Re ECCS Surveillance Requirements

ML20005E215
Person / Time
Site:	Beaver Valley
Issue date:	12/21/1989
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20005E208	List: ML20005E207 ML20005E209 ML20005E215
References
NUDOCS 9001040101
Download: ML20005E215 (8)

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o, 4 ATTACHMENT A-1 1:  ;

b' Revise the Beaver Valley Power Station, Unit No. 1 f Technical Specification as follows:  !

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9001040101 891221 PDR ADOCK 05000334 P FDC

r EMERGENCY CORE COOLING SYSTEMS l

SURVEILLANCE REQUIREMENTS (Continued) i

b. At least once per 31 days and within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each ,

solution volume increase of greater than or equal to 1% of~

tank volume by verifying the boron concentration of the accumulator solution.

c. At least once per 31 days when the RCS pressure is above 2000 psig by verifying that power to the isolation valve l '

operator control circuit is disconnected by removal of the plug in the lock out jack from the circuit. .

4.5.1.2 Each accumulator water level and pressure alarm channeln shall be demonstrated OPERABLE:

a. At least once per 31 days by the performance of a CHANNEL FUNCTIONAL TEST.

b. At least once per 18 months by the performance of a CHANNEL CALIBRATION.

4.5.1.3 During normal plant cooldown snd depressurization, each accumulator discharge isolation valve [MOV-1SI-865A, B and c) shall be verified to be closed and de-energized when RCS preasure is

-reduced to 1,000 1 100 psig.

BEAVER VALLEY UNIT 1 3/4 5-2 PROPOSED WORDING l

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ATTACHNENT A-2 Revise the Beaver Valley Power. Station, Unit No. 2 l;i Technical specification as follows:

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. Attachment B Proposed Technical Specification Change Unit No. 1 - Change No. 172 Unit No. 2 - Change No. 33

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Safety Analysis

, Description of Amendment Reauest; The proposed amendment would revise the dufety Injection System Accumulators surveillance requirements for the Beaver ,

Valley Unit 1 and Unit 2 Technical Specifications. This revision would delete surveillance requirement 4.5.1.d which verifies that the accumulator isolation valves automatically open upon receipt of a safety injection signal and when the RCS pressure exceeds the P-11 interlock setpoint. This amendment would also correct a typographical error in the Unit 1 surveillance requirement 4.5.1.c. ,

t Discussion The accumulator discharge isolation valves are motor operated valves which are open and the power to operate the valves is de-energized during normal' plant operation. Power to these valves is removed during operation to prevent any spurious signals from inadvertently closing the valves. In Unit 1, a lock-out jack plug in ~the control room is removed which removes power from the contactor coils to ensure the valves will not operate. In Unit 2, a separate slave contactor is de-energized via a lock-out jack plug in the control room which removes power to the valve.

As part of the plant normal shutdown procedures, these valves are momentarily energized, closed and then de-energized again at approximately 1000 psig pressure in the RCS (per Technical Specification surveillance requirement 4.5.1.3) to prevent a loss of accumulator water inventory to the RCS when depressurizing the plant. During startup, these valves are momentarily energized, L opened and then de-energized again at approximate 3y 1000 psig pressure in the RCS.

The accumulator isolation valves for both units have redundant valve position indicating lights in the control room. In Unit 1, l the position indication is operated by independent limit switches in the motor operator. In Unit 2, one set of position indicators is operated by the motor operator limit switches. The second set of indication is operated by stem mounted limit switches powered by a separate 120 VAC power supply. In both units, the redundant valve position indicators are available in the control room while the power lock-out jack plugs are removed. Each control room also contains an annunciator which will alarm should any of the accumulator isolation valves not be fully opened with the RCS at pressure (the pressure at which the safety injection block is unblocked). This alarm will reflash every hour after the alarm is acknowledged until the valve is properly positioned.

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' EMERGENCY CORE C00L'ING SYSTEMS l -SURVEILLANCE RFOUIREMENTE (cantinuadi c.- Atleastonceper31dayswhentheRCSpressureisabova1.00d.~

psig by verifying that power to the isolation valve operator l control circuit is disconnected by removal of the plug in the lock out jack from the circuit.

[d. At least once per 18 months by verifying that each accumulator d* g'

( . isolation valve opens automatically under each of the following conditions:

1) When an actual or a simulated RCS pressure signal exceeds the P-11 (Pressurizer Pressure Block of Safety Injection)

Setpoint, and

2) Upon receipt of a Safety Injection test signal.

4.5.1.2 Each accumulator water level and pressure alare channel shall be demonstrated OPERABLE:

a. At'least once per 31 days by the performance of a CHANNEL FUNCTIONAL TEST.

b. At least once per 18 months by the performance of a CHANNEL CALIBRATION.

4. 5.1. 3 During normal plant cooldown and depressurization, each accumulator discharge isolation valve 2 SIS-MOV 865 A, B and C shall be verified to be closed and de-energized when RCS pressure is reduced to 1,000 t 100 psig.

BEAVER VALLEY - UNIT 2 3/4 5-2 -

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. Page 2 These valves receive a safety injection signal to ensure that they are open in the event of'an accident which initiates a safety- '

injection. They also automatically open if the RCS pressure exceeds the P-11 interlock setpoint. However, with the power removed. from these valves via the lock-out jacks, neither opening signal is functional. Therefore, performances of surveillance requirement 4.5.1.d should not be necessary.

Adequate surveillance requirements currently . exists in specification 3.5.1 to ensure that these valves will be opened.

Surveillance requirement 4.5.1.a.2 requires that the isolation valves be verified open every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Redundant control room valve position indication (as discussed above) is available for.

this surveillance. Surveillance requirement 4.5.1.c specifies removal of the lock-out jack plugs in the valve control circuits and requires this surveillance be performed every 31 days. This ensures that the valves will not be inadvertently mis-positioned. ,

should these valves not be in their proper position, the control room annunciator would alert the operator.

Removal of surveillance requirement 4.5.1.d would also reduce the potential for inadvertent plant safety injections during testing performed to satisfy this surveillance. Surveillance 4.5.1.d.1 is performed during startup by closing each accumulator isolation valve individually and cycling the plant pressure above the 2000 psig setpoint three times to test each valve. When increasing pressure above 2000 psig, the safety injection block is automatically defeated. Therefore, this test requires manual actions by the operator during each pressure decrease to re-instate the safety injection block to prevent an inadvertent

safety injection. It should also be noted that performance of this test requires each isolation valve to be closed to demonstrate the auto opening of the valve. Thic is a violation of the LCO and places the plant in an action statement. Due to the g wiring arrangement of this control circuit, no other means is

! available to test this interlock without involving the significant use of jumpers and lifted leads.

L A previous request to remove surveillance requirement 4.5.1.d

! in the Unit 1 Technical Specifications was submitted to the NRC in 1987. As discussed in the NRC Safety Evaluation for Amendment  !

No. 120, the NRC Staff concluded that they would not act on this 1 part of the amendment request. The basis for this decision was l that the functional requirement of the safety injection signal and l P-11 interlock signal to the isolation valves is included in Branch Technical Positions ICSB 4 and 18. It is our position that the requirements of BTP ICSB 4 should not be applied in this  !

situation since the opening and power lock-out of these valves removes the concern for " operating bypasses" discussed in IEEE Std 279. This treatment of these valves as passive valves is  !

consistent with our approved ASME Section XI testing program which j considers these valves as open and passive.

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With 'the proposed amendment,-the Technical-~ Specifications will- I continue to ensure that the safety injection accumulators are l available with the accumulator isolation valves opened and remove

. unnecessary testing which increases the potential for inadvertent --

safetyL injections and entry,into an action statement. . This change is therefore considered safe.

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ATTACHMENT C No Significant Hazard Evaluation Proposed Technical Specification Change Unit No. 1 - Change No. 172 I' Unit NO. 2 - Chance No. 33 Basis for _ Proposed No Significant Hazards Consideration Determination: The commission has provided standards for determining whether a significant hazards consideration exists (10CFR50.92(c)). ,

A proposed amendment to an operating license for a facility involves l no significant hazards consideration if operation of the facility in 1 accordance with the ' proposed amendment would not (1) involve a i significant increase in the probability or consequences of an accident previously evaluated: (2) create the possibility of a new or_ different kind of accident form any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed change does not involve a significant hazards consideration because:

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1. -This change will not reduce the reliability or availability of the safety injection accumulators. The Technical Specifications as revised will continue to ensure that the safety injection accumulators are available to assist in the mitigation of any postulated loss of coolant accidents as assumed in the accident analyses. Deletion of the auto opening signals surveillance requirements for the accumulator isolation valves will therefore not involve a significant increase in the probability or consequences of an accident previously evaluated. The accumulator availability will be increased because of reduced testing with the discharge valves closed.

2. This change would not create the possibility of a new or different kind of accident from any accident previously evaluated. There would be no change to system configurations, plant equipment or analysis as a result- of this propoced amendment.

3. This change would not involve a significant reduction in a margin of ~ safety. The proposed Technical Specification will continue to ensure the operability of the safety injection accumulators and will not reduce their effectiveness to assist in mitigating the consequences of any postulated loss of coolant accident. Plant design features and routine verification of valve position assure proper at-power accumulator valve positioning. This change, if accepted, would act to reduce: the potential for unnecessary plant challenges, i.e. forced shutdown if the accumulator discharge valve failed to re-open during testing, unnecessary pressurization and depressurization of the reactor coolant system to accommodate testing and the potential for a safety injection during testing.

Based on the above considerations, it is proposed to characterize the change as involving no significant hazards considerations.

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