ML20006F924

Application for Amend to License DPR-16,consisting of Tech Spec Change Request 183,permitting No Limitation on Number of Inoperable Position Indicators for Sixteen ASME Code Safety Valves During Power Operation

ML20006F924
Person / Time
Site:	Oyster Creek
Issue date:	02/15/1990
From:	Fitzpatrick E GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20006F919	List: ML20006F918 ML20006F924 ML20006F959
References
NUDOCS 9003010359
Download: ML20006F924 (5)

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' CPU NUCLEAR CORPORATION ..

OYSTER CREEK NUCLEAR CENERATING STATION Provisional Operating License No. DPR-16 '

i Technical Specification  ;

Change Request No. 183 -

Docket No. 50-219 Applicant submits, by this Technical Specification change Request No. 183 to the Oyster Creek Nuclear Generating Station Technical Specifications, proposed changes to pages 3.13-1 and 3.13-2.

By f E. E. Fitzpatrick Vice President and Director, Oyster Creek Sworn and Subscribed to before me this /IN day of _, 1990.

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A Notary Publig of NJ OfANA M DeLLAsjo NOTARY PUBUC Of NEW JERSEY

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5 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i In the matter ) Docket No. 50-219 ,

GPU Nuclear Corporation )

CERTIFICATE OF SERVICE ,

This is to certify that a copy of technical Specification Change Request No.

183 for oyster Creek Nuclear Generating Station Technical Specifications, filed with the U.S. Nuclear Regulatory Commission on February 15 , 1990, has this day of February 15 , 1990, been served on the Mayor of Lacey Township,

' Ocean County, New Jersey by deposit in the United States mail, addressed as

• follows:

The Honorable Debra Madensky i Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 ,

8 By l E. E. Fitzpatridk Vice President and Director, >

Dyster Creek f i

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'.fi *i CYSTER CREEK NUCLEAR CENERATING STATION L .,- PROVISIONAL OPERATING LICENSE N0. DPP-16

. DOCKET NO. 50-219

, . TECHNICAL SPECIFICATION CHANGE REQUEST.NO. 183

~p Applicant hereby requests the Commission to change Appendix A to the above captioned license as below, and pursuant to 10 CFR 50.91,.an analysis concerning the determination of no significant hasards considerations is also

. presented:

-1. Section to be Chanced

[ Section 3.13-

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'2. Extent of Chance p Revise Technical Specifications 3.13.B.1 and 3.13.B.2. Deleto current

!; Technical Specifications 3.13.B.3 and 3.13.B.4.and the note at tho' bottom of Page 3.13-1 which applied only during the previous operating b '

cycle. A minor change to the associated bases will also be'made. In.

addition, where Technical Specification definitions are used in

p. Specifications'3.13.D, 3.13.E, 3.13.F and 3.13.0 they are now capitalized.

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3. Chances Recuested The requested changes are shown on attached Technical Specification pages 3.13-1, 3.13-2 and 3.13-3. Proposed Specification 3.13.B.2 would replace current Specifications 3.13.B.2, 3.13.B.3, and 3.13.B.4 and place no' limit on the number of safety valve position' indicators during j operating periods between cold shutdowns.

4. Discussion

.As a result'of Recommendation 2.1.3.a described in NUREG 0578, valve position indicating devices (acoustic monitors) were inctalled on the five Electromatic Relief Valves (EMRV) and the sixteen Code safety

. valves at Oyster Creek in 1980. Operability and surveillance L requirements for these devices were= subsequently incorporated into the F Technical Specifications. Each valve has a primary device (acoustic monitor) and a backup device (thermocouple)., A control room alarm is

.provided for the acoustic monitors while thermocouple indication of tailpipe temperature is provided at a local panel on the 23 foot elevation in the reactor building. These devices provide a means for l direct indication of valve' position. This change request concerns the Technical Specification Limiting Conditions for Operation for the safety valve position indicators only and are contained in Technical Specification Section 3.13.B. In addition, a non-substantive administrative change to Technical Specification Sections 3.13.D,

-3.13.E, 3.13.F and 3.13.G would highlight Technical Specification 3 definitions, by the use of capital letters, where they appear in the

Specifications in those sections.

1.

l. The addition of the acoustic monitors to the 16 safety valves was I"- frequired by NUREG 0737, ITEM II.D.3, in order to provide direct l indication of safety valve position to the operator in the control room. The basic requirement was to provide the operator with

=c unambiguous indication of whether the valve was open or closed so that the operator could take appropriate actions.

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In cdditiCn, NURE3-0737 requircd planto to teveltp cymptom-b2:ed j

. Emergency Operating Procedures (EOPs) to provide better operator 1'

, guidance in coping with transients and accidents. Dyster Creek has implemented symptom-based EOPs based on the BWR Owners Group generic 4 Emergency Procedure Guidelines. I The 16 safety valves at Oyster Creek are spring-loaded and do not have l any mechanism fcr remote operator control of the valve's position from the control room. This means that if a safety valve has inadvertently opened or is stuck open, the operator cannot take any direct action to i close the valve. The derived benefit is information only. ,

I The control room alarm response procedure alerts the operator to an open safety valve based on the acoustic monitors. The procedure does not  !

direct the operator to take any action other than to confirm that the '

valve did open based on increasing drywell pressure or an increase in i safety valve discharge thermocouple reading.

After developing the symptom-based EOPs, it was determined that safety valve position indication is no longer necessary based on the manner in ,

which the EOPs direct the operator's actions. The EOPs instruct the operator to respond to plant parameters without the need to diagnose the event. The operator takes actions to control reactor vessel and containment conditions to bring these parameters under control. The operator's actions in response to a loss of reactor vessel water inventory are the same regardless of the source of the inventory loss.

The discharge of steam to the drywell from the opening of a safety valve or any other primary system leakage path would be immediately evident to the operator by a rapid increase in drywell pressure and atmospheric temperature. The high drywell pressure condition is an entry point into

• l both the RPV (reactor pressure vessel) control and containment control  ;

i procedures. The RPV control procedure directs the operator to control .

RPV water level and pressure and confirm reactor shutdown. The containment control procedure gives the operator guidance for controlling drywell pressure and temperature and torus pressure, temperature and water level. The presence of the safety valve acoustic monitor alarm does not alter the operator actions in controlling the changes in plant parameters during an event.

In summary, with the development and implementation of symptom-based emergency operating procedurso, the operators response is governed by changes in plant parameters (symptoms) and not by what caused those parameters to change. Consequently, operator response to a stuck open safety valve is not affected or dependent on the operability of the valve acoustic monitors or thermocouples. Thus, operability of safety valve position indication is not necessary for transient or accident mitigation and Technical specifications for safety valve position 7

indication should not require a plant shutdown or necessitate power reduction in order to ensure compliance.

In order t3 be ccncictent with th9 requirement 3 cf NURE3 0737, Item

. II.D.3, the proposed Technical Specifications will still require that all reafety valve position indication instrumentation be operable prior to startup following each cold shutdown. If a backup instrument becomes inoperable, no compensatory measures would be required. If a primary instrument becomes inoperable, the acoustic monitor on an adjacent

'j valve, if operable, would have its setpoint reduced. A setpoint reduced in this manner would be allowed to return to normal if the acoustic

!: monitor alarms due to background noise. This ensures the continued operability of the adjacent valve's acoustic monitor.

5. Determination We have determined that the proposed Technical Specification change involves no significant hazards considerations as discussed below.

1. Tha proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.

Since no hardware modifications are associated with this change and since safety valve position indication is only a monitoring system, the operability of the monitoring system does not affect or prevent the function of the safety valves. Therefore, the probability of any accident is unaltered. As no automatic action is associated with safety valve position indication instrumentation and system and operator actions are not altered by knowledge of safety valve position, the consequences of any accident will not increase.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated since the function of the safety valves is unchanged. The state of -l operability of safety valve position indication instrumentation does  ;

not affect any system and aF such will not alter any safety system function used to mitigate any accident. Further, the operator is not dependent upon this indication for event mitigation actions.

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3. Safety system and operator response to a stuck open safety valve is .

not affected or dependent on the operability of safety valve position indication. The Technical Specification basis for safety valve position indication instrumentation currently reflects that operator response does not rely upon safety valve position indication. In addition, safety valve actuation setpoints are not changed. Therefore, there is no reduction in margin of safety.

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