ML020420166
| ML020420166 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/14/2002 |
| From: | Sands S NRC/NRR/DLPM/LPD3 |
| To: | Bergendahl H FirstEnergy Nuclear Operating Co |
| Sands S, NRR/DLPM/415-3154 | |
| References | |
| TAC MB1979 | |
| Download: ML020420166 (14) | |
Text
February 14, 2002 Mr. Howard W. Bergendahl Vice President-Nuclear, Davis-Besse FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State Route 2 Oak Harbor, OH 43449-9760
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - ISSUANCE OF AMENDMENT (TAC NO. MB1979)
Dear Mr. Bergendahl:
The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 251 to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, Unit 1. The amendment revises the Technical Specifications in response to your application dated May 15, 2001, and supplemented by letter dated February 8, 2002.
This amendment revises Technical Specification (TS) 3/4.9.4, Refueling Operations -
Containment Penetrations, TS 3/4.9.12, Refueling Operations - Storage Pool Ventilation, and associated Bases. The changes will allow the containment equipment hatch cover to be removed during core alterations and movement of irradiated fuel inside containment provided the Emergency Ventilation System is operable with the ability to filter any radioactive release.
A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
Stephen P. Sands, Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-346
Enclosures:
- 1. Amendment No. 251 to License No. NPF-3
- 2. Safety Evaluation cc w/encls: See next page
February 14, 2002 Mr. Howard W. Bergendahl Vice President-Nuclear, Davis-Besse FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State Route 2 Oak Harbor, OH 43449-9760
SUBJECT:
DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - ISSUANCE OF AMENDMENT (TAC NO. MB1979)
Dear Mr. Bergendahl:
The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 251 to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, Unit 1. The amendment revises the Technical Specifications in response to your application dated May 15, 2001, and supplemented by letter dated February 8, 2002.
This amendment revises Technical Specification (TS) 3/4.9.4, Refueling Operations -
Containment Penetrations, TS 3/4.9.12, Refueling Operations - Storage Pool Ventilation, and associated Bases. The changes will allow the containment equipment hatch cover to be removed during core alterations and movement of irradiated fuel inside containment provided the Emergency Ventilation System is operable with the ability to filter any radioactive release.
A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
Stephen P. Sands, Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-346 DISTRIBUTION:
PUBLIC R. Hager
Enclosures:
- 2. Safety Evaluation S. Sands OGC T. Harris G. Grant, RIII cc w/encls: See next page W. Beckner G. Hill (2)
Package Accession Number: ML020580453 ADAMS Accession Number: ML020420166 TS Accession Number: ML020460292 OFFICE PM:LPD3 LA:LPD3 SC:SPLB SC:SPSB OGC SC:LPD3 NAME SSands THarris** RHager* FReinhart** JMoore** AMendiola DATE 02/13/02 02/11/02 02/4/02 02/11/02 02/13/02 02/14/02 OFFICIAL RECORD COPY
- See RHager to AMendiola memo of 2/4/02
- See previous concurrence
Mr. Howard Bergendahl Davis-Besse Nuclear Power Station, Unit 1 FirstEnergy Nuclear Operating Company cc:
Mary E. OReilly Dennis Clum FirstEnergy Radiological Assistance Section Supervisor 76 South Main Street Bureau of Radiation Protection Akron, OH 44308 Ohio Department of Health P.O. Box 118 Manager - Regulatory Affairs Columbus, OH 43266-0118 FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Carol OClaire, Chief, Radiological Branch 5501 North State - Route 2 Ohio Emergency Management Agency Oak Harbor, OH 43449-9760 2855 West Dublin Granville Road Columbus, OH 43235-2206 Director Ohio Environmental Protection Agency Ohio Department of Commerce DERR--Compliance Unit Division of Industrial Compliance ATTN: Zack A. Clayton Bureau of Operations & Maintenance P.O. Box 1049 6606 Tussing Road Columbus, OH 43266-0149 P.O. Box 4009 Reynoldsburg, OH 43068-9009 Public Utilities Commission of Ohio Transportation Department Regional Administrator 180 East Broad Street U.S. Nuclear Regulatory Commission Columbus, OH 43215-3793 801 Warrenville Road Lisle, IL 60523-4351 Attorney General Department of Attorney Michael A. Schoppman 30 East Broad Street Framatome ANP Columbus, OH 43216 1911 N. Ft. Myer Drive Rosslyn, VA 22209 President, Board of County Commissioners of Ottawa County Resident Inspector Port Clinton, OH 43252 U.S. Nuclear Regulatory Commission 5503 North State Route 2 Oak Harbor, OH 43449-9760 Plant Manager, Randel J. Fast FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State - Route 2 Oak Harbor, OH 43449-9760
FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-346 DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 251 License No. NPF-3
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by the FirstEnergy Nuclear Operating Company (the licensee) dated May 15, 2001, and supplemented by letter dated February 8, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. NPF-3 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 251, are hereby incorporated in the license. FirstEnergy Nuclear Operating Company shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of the date of issuance and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Anthony J. Mendiola, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: February 14, 2002
ATTACHMENT TO LICENSE AMENDMENT NO. 251 FACILITY OPERATING LICENSE NO. NPF-3 DOCKET NO. 50-346 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert 3/4 9-4 3/4 9-4 3/4 9-12 3/4 9-12 B 3/4 9-1a B 3/4 9-1a B 3/4 9-3 B 3/4 9-3
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 251 TO FACILITY OPERATING LICENSE NO. NPF-3 FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 DOCKET NO. 50-346
1.0 INTRODUCTION
By application dated May 15, 2001, and supplemented by letter dated February 8, 2002, FirstEnergy Nuclear Operating Company (the licensee) requested an amendment to Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station. This proposed amendment would revise Technical Specification (TS) 3/4.9.4, Refueling Operations - Containment Penetrations, TS 3/4.9.12, Refueling Operations - Storage Pool Ventilation, and associated Bases. The changes would allow the containment equipment hatch cover to be removed during core alterations and movement of irradiated fuel inside containment provided the Emergency Ventilation System is operable with the ability to filter any radioactive release.
The supplemental information contained clarifying information and did not change the initial no significant hazards consideration determination and did not expand the scope of the original Federal Register notice.
2.0 BACKGROUND
During refueling outages, TS 3.9.4 requires the containment equipment hatch cover to be closed and held in place with a minimum of four bolts during core alterations or during movement of irradiated fuel inside containment. Typically, 120-150 hours are required to perform fuel movement during a refueling outage. With the containment equipment hatch cover closed during this time, other outage maintenance and modification activities within the containment are impacted due to the loss of this larger access opening for moving equipment in and out of containment. The proposed TS changes will allow the containment equipment hatch cover to be open during core alterations and the movement of irradiated fuel inside containment.
The containment equipment hatch opens into the fuel handling area, which contains the spent fuel pool, cask pit, and transfer pit. With the containment equipment hatch closed, the hatch cover is part of the fuel handling area ventilation system (FHAVS) negative pressure boundary.
With the containment equipment hatch open, the FHAVS negative pressure boundary extends to include the inside of the containment pressure vessel. On a high radiation signal the FHAVS exhaust will be redirected to the suction of the emergency ventilation system (EVS). The EVS can draw air from the fuel handling area and filter it through a high-efficiency particulate air
(HEPA) filter and charcoal adsorbers prior to exhausting the air to the outside. According to the licensee, the EVS is adequately sized and designed to filter the radioactivity released during a fuel handling accident inside containment.
3.0 EVALUATION The licensees proposal to conduct refueling operations (i.e., core alterations or movement of irradiated fuel inside containment) with the containment equipment hatch open is needed to support more efficient (i.e., shorter) refueling outages. The staff finds the proposed changes to be in general agreement with the closure requirements specified in the Reviewers Note in Technical Specification Task Force Traveler 51, Revised Containment Requirements During Handling Irradiated Fuel and Core Alterations. The staffs review focused on the fuel-handling accident (FHA) inside containment, the FHA in the fuel handling area (i.e., outside containment), and whether the proposed changes to the TS adequately support the proposed changes in refueling operations.
3.1 Dose Considerations The licensee has previously analyzed two different FHAs in the Davis-Besse updated safety analysis report (USAR). The current Davis-Besse FHA inside containment analysis as described in the USAR does not take credit for containment closure or filtration of the release and was performed in accordance with the guidance in Regulatory Guide 1.25, Assumptions Used for Evaluating the Potential Radiological Consequences of a Fuel Handling Accident in the Fuel Handling and Storage Facility for Boiling and Pressurized Water Reactors. The licensees calculated thyroid and whole body dose results were well within the limits of 10 CFR Part 100. A control room habitability analysis, using the same assumptions, was performed to support Amendment 202 which allows both doors of the personnel airlock to be open during fuel movement. The licensees calculated thyroid and whole body dose results were within the limits of GDC-19, Control Room.
The current Davis-Besse USAR analysis of a FHA in the fuel handling area takes credit for filtration of the release via the EVS and assumes 95 percent efficient iodine filtration. The licensees calculated thyroid and whole body dose results for this FHA were also well within the limits of 10 CFR Part 100. The current model only assumes that the EVS draws suction from the fuel handling area. Under the proposed changes, the licensee asserts that the EVS is capable of drawing down the combined space of the fuel handling area and containment to the necessary negative pressure so that filtration of the release can be assumed.
Control room habitability was not an issue for this review because the control room ventilation system operation and expected radiological release (i.e., dose) would not be altered by the proposed changes.
Based on the above discussion, the staff has reasonable assurance that the radiological consequences of postulated design-basis FHAs remain within the dose guidelines given in 10 CFR Part 50, Appendix A, GDC-19 for the control room and well within the offsite dose guidelines given in 10 CFR Part 100.
3.2 Technical Specification Changes The proposed changes to the TSs were reviewed to ensure that adequate isolation provisions could be attained in the event of a FHA with the containment equipment hatch open and the personnel air lock doors open.
The licensee evaluated the use of plant personnel to close the containment equipment hatch in the event of a FHA. However, the licensees calculations indicated that reinstalling the containment equipment hatch under design-basis FHA conditions, could result in plant personnel receiving in excess of 20 rem total effective dose equivalent. Considering that the EVS is available to mitigate the consequences of a FHA inside containment, the licensee has concluded that reinstalling the equipment hatch during FHA conditions is not warranted. The licensee will revise its procedures to evacuate the fuel handling area following a FHA inside containment if the equipment hatch cover has been removed. The staff finds the licensees position to be reasonable and acceptable.
3.3 TS 3/4.9.4, Refueling Operations - Containment Penetrations:
The licensee proposes to modify the limiting condition for operation (LCO) to permit opening the equipment hatch during refueling operations. The LCO currently states:
3.9.4. The containment penetrations shall be in the following status:
- a. The equipment door closed and held in place by a minimum of four bolts.
The proposed LCO states:
3.9.4. The containment penetrations shall be in the following status:
- a. The equipment hatch cover closed and held in place by a minimum of four bolts, except the equipment hatch may be open provided the requirements of Specification 3.9.12 are satisfied.
Sections b. and c. of the LCO, the Applicability statement, the Action, and the Surveillance Requirements remain unchanged. The TS Bases will be modified to accommodate the proposed LCO.
As discussed above, the containment equipment hatch opens into the fuel handling area and any release can be filtered though the EVS prior to release into the environment. Penetrations in the fuel handling area are controlled by procedure to ensure compliance with TS 3.9.12, Storage Area Ventilation. TS 3.9.12 ensures that the EVS is capable of maintaining a negative pressure in the fuel handling area of 1/8" water gauge. Proposed TS 3.9.4 and proposed TS 3.9.12, which is discussed below, provide for immediate closure of the personnel air lock leading into containment and the redirection of any release through a filtered ventilation system in the event of a FHA in containment.
3.4 TS 3/4.9.12, Refueling Operations - Storage Pool Ventilation The licensee proposes to modify TS 3.9.12 to allow one train of EVS to be considered OPERABLE if the EVS train cannot meet the drawdown requirements of Surveillance Requirement (SR) 4.9.12.1 solely because the containment equipment hatch and both containment air lock doors are open, provided TS 3.9.4.b is met. TS 3.9.4.b requires that a minimum of one door in each containment air lock be closed, but both doors of the containment personnel air lock can be open if a designated individual is available immediately outside the personnel air lock to close the door.
TS SR 4.9.12.1 requires, in part, that the EVS servicing the storage pool area be demonstrated operable by verifying that the EVS maintain the storage pool area at a negative pressure of
1/8" water gauge relative to the outside atmosphere during system operation. As described in the licensees letter dated February 8, 2002, this SR is required to be performed with the equipment hatch cover removed prior to taking any of the following actions with the equipment hatch cover removed: core alterations or moving irradiated fuel within the containment; moving fuel in the spent fuel pool, cask pit, or transfer pit; or performing crane operations over the spent fuel pool, cask pit, or transfer pit containing irradiated fuel. Performance of SR 4.9.12.1 with the equipment hatch cover removed will require the EVS to take suction from the combined containment and fuel pool storage area volumes. This will demonstrate that a negative pressure can be obtained, thus ensuring that any release from a FHA will be processed through the appropriate filters. The licensees letter further states that the appropriate surveillance test procedure is being updated to include the requirement to perform SR 4.9.12.1 with the equipment hatch cover removed if the actions itemized above will be performed with the equipment hatch cover removed. The staff concludes that performance of SR 4.9.12.1 with the equipment hatch cover removed is both appropriate and necessary if refueling activities are planned to be performed with the equipment hatch cover removed.
3.4.1 Changes to LCO The licensee proposed to modify the LCO to permit continued plant operation with the containment equipment hatch and both personnel air lock doors open. The current LCO 3.9.12 states:
3.9.12 Two independent emergency ventilation systems servicing the storage pool area shall be OPERABLE.
The proposed LCO 3.9.12 states:
3.9.12 Two independent emergency ventilation systems servicing the storage pool area shall be OPERABLE. When an emergency ventilation system servicing the storage pool is incapable of meeting the acceptance criteria of Surveillance Requirement 4.9.12.1 solely because the containment equipment hatch is open and both doors of the containment personnel air lock are open, it may be considered OPERABLE provided that at least one personnel air lock door is capable of being closed and a designated individual is available immediately outside the personnel air lock to close the door.
The proposed change allows for the containment equipment hatch and both containment airlock doors to be open as allowed by the proposed TS 3.9.4 while maintaining the ability to redirect any release through a filtered ventilation system in the event of a FHA. Since the proposed TS 3.9.12 and the current TS 3.9.4 requires a designated individual to be available immediately outside the personnel air lock to close a door and at least one door is capable of being closed in the event of a FHA, the period of time the EVS will not be able to perform its function will be minimal. The proposed change is acceptable as it has a minimal impact on the current TS and ensures timely restoration of the ventilation boundary in the event of a FHA.
3.4.2 Changes to Applicability Statement The current Applicability Statement to TS 3.9.12 states:
APPLICABILITY: Whenever irradiated fuel is in the spent fuel pool or cask pit.
The proposed Applicability Statement to TS 3.9.12 states:
APPLICABILITY: Whenever irradiated fuel is in the spent fuel pool or cask pit, or during CORE ALTERATIONS or movement of irradiated fuel within the containment with the containment equipment hatch open.
The staff finds the proposed change to the Applicability statement acceptable because it reflects the need for the EVS to be operable during refueling activities with the equipment hatch open.
3.4.3 Changes to the Action Statements 3.4.3.1 The licensee proposes to add the following Action Statement to TS 3.9.12:
- b. With one emergency ventilation system servicing the storage pool inoperable, CORE ALTERATIONS and fuel movement within containment may proceed provided either the OPERABLE emergency ventilation system servicing the storage pool area is in operation and discharging through at least one train of HEPA filters and charcoal adsorbers or the containment equipment hatch is closed and held in place by a minimum of four bolts.
The proposed Action statement is consistent with the requirements for the current Action Statement a. which deals with activities in the fuel handling area with one EVS train inoperable.
The requirement to have the remaining EVS train operating ensures that no undetected failures have occurred affecting the OPERABILITY of that train and any active failures will be detected.
Also, if the equipment hatch is closed, the EVS is no longer required to mitigate a FHA in containment. The proposed Action statement is acceptable.
3.4.3.2 The licensee proposes to change the current TS Action Statement 3.9.12.b.
The current Action Statement states:
- b. With no emergency ventilation system servicing the storage pool area
OPERABLE, suspend all operations involving movement of fuel within the spent fuel pool or cask pit, or crane operation with loads over the spent fuel pool or cask pit, until at least one system is restored to OPERABLE status.
The proposed Action Statement states:
- c. With no emergency ventilation system servicing the storage pool area OPERABLE, suspend CORE ALTERATIONS and all operations involving movement of fuel within the containment, spent fuel pool or cask pit, or crane operation with loads over the spent fuel pool or cask pit, until at least one system is restored to OPERABLE status. CORE ALTERATIONS and fuel movement within containment may proceed provided the containment equipment hatch cover is closed and held in place by a minimum of four bolts.
The proposed change reflects the new application of the EVS during refueling activities with the equipment hatch open. The addition of the statement CORE ALTERATIONS and fuel movement within containment may proceed provided the containment equipment hatch cover is closed and held in place by a minimum of four bolts is acceptable because closing the equipment hatch cover door ensures that means are available to mitigate the consequences of a FHA inside containment.
In summary, the staff concludes that the licensee has adequately addressed the dose consequences of a FHA with the equipment hatch cover removed and that the proposed TS changes ensure that adequate isolation provisions will be available. The staff also finds that the licensees proposed TS changes and procedural changes will adequately support refueling operations with the containment equipment hatch cover removed during Core Alterations or movement of irradiated fuel inside containment. Therefore, based on the above evaluation, the staff finds the licensees proposed changes acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Ohio State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
This amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluent that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (66 FR 34284). Accordingly, the amendment 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 the amendment.
6.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: David Cullison, Plant Systems Branch, NRR Michelle Hart, Probabilistic Safety Assessment Branch, NRR Date: February 14, 2002