ML043580232

License Amendment Application to Revise Technical Specification (TS) 3/4.9.2, Refueling Operations Instrumentation (License Amendment Request (LAR) 02-0006)

ML043580232
Person / Time
Site:	Davis Besse
Issue date:	12/20/2004
From:	Bezilla M FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
309300
Download: ML043580232 (24)

Text

FENOC FirstEnergy Nuclear Operating Company 5501 North State Route 2 Oak Harbor, Ohio 43449 Mark B. Bezilla Vice President - Nuclear 419-321-7676 Fax: 419-321-7582 Docket Number 50-346 10 CFR 50.90 License Number NPF-3 Serial Number 3093 December 20, 2004 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

Davis-Besse Nuclear Power Station License Amendment Application to Revise Technical Specification (TS) 3/4.9.2, Refueling Operations - Instrumentation (License Amendment Request (LAR) 02-0006)

Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, the following amendment is requested for the Davis-Besse Nuclear Power Station, Unit I (DBNPS). The proposed amendment would revise Technical Specification (TS) 3/4.9.2, Refueling Operations - Instrumentation, to more closely match the Improved Standard Technical Specifications (ISTS).

Enclosure I to this letter contains the technical justification for these proposed changes and the proposed no significant hazards consideration determination. FirstEnergy Nuclear Operating Company (FENOC) requests that this license amendment be approved by November 30, 2005.

Once approved, the amendment will be implemented within 120 days.

The proposed changes have been reviewed by the DBNPS onsite review board and the offsite nuclear review board.

Should you have any questions or require additional information, please contact Mr. Henry L.

Hegrat, Supervisor-Fleet Licensing, at (330) 315-6944.

Docket Number 50-346 License Number NPF-3 Serial Number 3093 Page 2 The statements contained in this submittal, including its associated enclosures and attachments, are true and correct to the best of my knowledge and belief. I am authorized by the FirstEnergy Nuclear Operating Company to make this submittal. I declare under penalty of perjury that the foregoing is true and correct.

Executed on:

Jeccent t

t By:

Mark B. Bezilla, Vice Preside -Nuclear MSH Enclosures cc:

Regional Administrator, NRC Region III J. B. Hopkins, NRC/NRR Senior Project Manager D. J. Shipley, Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

C. S. Thomas, NRC Region III, DB-1 Senior Resident Inspector Utility Radiological Safety Board

Docket Number 50-346 License Number NPF-3 Serial Number 3093 DAVIS-BESSE NUCLEAR POWER STATION EVALUATION FOR LICENSE AMENDMENT REQUEST NUMBER 02-0006 (20 pages follow)

LAR 02-0006 Page 1 DAVIS-BESSE NUCLEAR POWER STATION EVALUATION FOR LICENSE AMENDMENT REQUEST NUMBER 02-0006

Subject:

License Amendment Application to Revise Technical Specification (TS) 3/4.9.2, Refueling Operations - Instrumentation

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration (NSHC) 5.2 Applicable Regulatory Requirements/Criteria

7.0 REFERENCES

8.0 ATTACHMENTS

LAR 02-0006 Page 2

1.0 DESCRIPTION

This letter is a request to amend the Davis-Besse Nuclear Power Station, Unit Number 1 (DBNPS) Facility Operating License Number NPF-3 Appendix A Technical Specifications (TS).

The proposed amendment would revise TS 3/4.9.2, Refueling Operations - Instrumentation, to more closely match the NUREG-1430 Improved Standard Technical Specifications (ISTS).

The existing Surveillance Requirement (SR) 4.9.2.b requires a CHANNEL FUNCTIONAL TEST within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the initial start of CORE ALTERATIONS.

Under the existing SR, the CHANNEL FUNCTIONAL TEST is'performed in anticipation of CORE ALTERATIONS. CORE ALTERATIONS may be rescheduled due to plant conditions or administrative reasons, resulting in an unnecessary repetition of the CHANNEL FUNCTIONAL TEST. The requested changes resolve this issue by eliminating the CHANNEL FUNCTIONAL TEST requirement, while at the same time bringing TS 3/4.9.2 into closer alignment with the ISTS.

2.0 PROPOSED CHANGE

The proposed changes affect TS 3/4.9.2, Refueling Operations - Instrumentation, as follows:

LIMITING CONDITION FOR OPERATION (LCO)

The existing DBNPS LCO 3.9.2 states "As a minimum, two source range neutron flux monitors, one from each side of the reactor core, shall be operating, each with continuous visual indication in the control room and one with audible indication in the containment and control room." The ISTS LCO 3.9.2 states "Two source range neutron flux monitors shall be OPERABLE." It is proposed to revise the DBNPS LCO to match the ISTS LCO, except that the condition regarding opposing monitors would be retained. The resulting LCO would read: "Two source range neutron flux monitors, one from each side of the reactor core, shall be OPERABLE."

ACTION The existing DBNPS LCO 3.9.2 ACTION statement states "With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes. The provisions of Specification 3.0.3 are not applicable."

The corresponding ISTS section is in tabular format. CONDITION A, "One [required]

source range neutron flux monitor inoperable" has two required ACTIONS, A.1 (Immediately) "Suspend CORE ALTERATIONS" and A.2 (Immediately) "Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1." CONDITION B, "Two

[required] source range neutron flux monitors inoperable" also has two required ACTIONS, B.1 (Immediately) "Initiate action to restore one source range neutron flux monitor to

LAR 02-0006 Page 3 OPERABLE status" and B.2 (Once per twelve hours) "Perform SR 3.9.1.1." ISTS SR 3.9.1.1 verifies that boron concentration is within the limit specified in the Core Operating Limits Report (COLR).

It is proposed to revise the DBNPS TS ACTION statement to be equivalent to the ISTS ACTION statement, but continue to use the DBNPS TS format and use the refueling boron concentration requirement specified in DBNPS LCO 3.9.1. The proposed action statement would read as follows:

a. With only one of the required OPERABLE source range neutron flux monitors,

1. Immediately suspend CORE ALTERATIONS, and

2. Immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than the RCS boron concentration requirement of LCO 3.9.1.

b. With no OPERABLE source range neutron flux monitor,

1. Perform ACTION a., and

2. Immediately initiate action to restore one source range neutron flux monitor to OPERABLE status, and

3. Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verify that the RCS boron concentration meets the requirement of LCO 3.9.1, using chemical analysis to determine the boron concentration of the reactor pressure vessel and the refueling canal.

SURVEILLANCE REQUIREMENTS It is proposed to revise the DBNPS surveillance requirements to be equivalent to the ISTS SRs, including deletion of the independent mention of the CHANNEL FUNCTIONAL TEST. Consistent with the ISTS, as well as the treatment of all the flux monitors listed in DBNPS TS Table 4.3-1, "Reactor Protection System Instrumentation Surveillance Requirements," the requested change also adds the ISTS exclusion of neutron detectors from the CHANNEL CALIBRATION. The proposed SRs would read as follows:

4.9.2 As a minimum, two source range neutron flux monitors, one from each side of the reactor core, shall be demonstrated OPERABLE by performance of:

a. Deleted

b. Deleted

c. A CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and

LAR 02-0006 Page 4

d. A CHANNEL CALIBRATION prior to entry into MODE 6 if not performed within the last 18 months. Neutron detectors are excluded from CHANNEL CALIBRATION.

Associated changes to the TS Bases would be made under the provisions of the TS Bases Control Program. These changes are expected to include additional detail, including a discussion of the visual and audible indication features formerly referenced in the LCO. The affected TS Bases pages are included in Attachment 3 for information.

In summary, the proposed amendment would revise TS 3/4.9.2, Refueling Operations -

Instrumentation, to more closely match the NUREG-1430 Improved Standard Technical Specifications (ISTS). Consistent with the ISTS, the changes eliminate the CHANNEL FUNCTIONAL TEST requirements in MODE 6 for source range indication.

3.0 BACKGROUND

The Nuclear Instrumentation System monitors reactivity conditions by detecting neutrons that leave the reactor core. The nuclear instruments monitor three overlapping ranges of flux: source range, intermediate range, and power range. There are two electrically and physically independent source range channels in the Nuclear Instrumentation System. The source range instrumentation sensors are high sensitivity proportional counters that monitor neutron flux over a range of I x 10.1 to I x 106 counts per second. Control Room indicators provide count rate and startup rate information for the operators. As depicted in Updated Safety Analysis Report (USAR) Figure 7.8-3, "Davis-Besse Nuclear Power Station Nuclear Instrumentation - Detector Locations," the source range detectors are located outside the reactor, approximately 180 degrees apart. USAR Section 7.8, "Nuclear Instrumentation (NI)," provides additional information on the design of this system.

The Post-Accident Monitoring System (PAMS) also monitors reactivity conditions. Two safety grade electrically and physically independent fission chamber instrument strings are provided.

The resulting signal is converted into source range (1 x 101-to 1 x 105 counts per second) and wide range indication. The signal processor also provides audible indication in the main control room and in containment. The Channel 1 PAMS detector is located near the corresponding Channel 2 NI detector, and the Channel 2 PAMS detector is located adjacent to the corresponding Channel I NI detector. USAR Section 7.13.3.11, "Neutron Flux Detectors,"

provides summary information on the PAMS neutron flux detectors.

The existing SR 4.9.2.b requires a CHANNEL FUNCTIONAL TEST within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the start of CORE ALTERATIONS.

Under the existing SR, the CHANNEL FUNCTIONAL TEST is performed in anticipation of CORE ALTERATIONS. However, CORE ALTERATIONS may be rescheduled due to plant conditions or administrative reasons, resulting in an unnecessary repetition of the CHANNEL FUNCTIONAL TEST.

LAR 02-0006 Page 5 The purpose of the proposed amendment is to revise TS 3/4.9.2, Refueling Operations -

Instrumentation, to eliminate the unnecessary repetition of the CHANNEL FUNCTIONAL TEST described above, and to more closely align TS 3/4.9.2 with the NUREG-1430 ISTS.

4.0 TECHNICAL ANALYSIS

The proposed changes are based on NUREG-1430, Revision 3, Standard Technical Specifications - Babcock and W~ilcox Plants.

LIMITING CONDITION FOR OPERATION The existing DBNPS LCO 3.9.2 states "As a minimum, two source range neutron flux monitors, one from each side of the reactor core, shall be operating, each with continuous visual indication in the control room and one with audible indication in the containment and control room." The ISTS LCO states "Two source range neutron flux monitors shall be OPERABLE." It is proposed to revise the DBNPS LCO to match the ISTS LCO, except that the condition regarding opposing monitors would be retained. The resulting LCO would read: "Two source range neutron flux monitors, one from each side of the reactor core, shall be OPERABLE."

The proposed changes will delete the words, "As a minimum." This is an editorial change for consistency with the ISTS and other similar sections in the DBNPS TS. It is understood that if three or four neutron flux monitors are OPERABLE, this meets the requirement to have two OPERABLE monitors.

The proposed changes will retain the words "one from each side of the reactor core," which is an appropriate plant-specific departure from the ISTS.

The DBNPS has four source range neutron flux monitors available to meet the LCO, two on each side of the reactor core. Requiring at least one OPERABLE monitor on each side of the core ensures that the neutron flux is appropriately monitored during refueling operations.

The proposed changes will change the word "operating" to "OPERABLE," consistent with the ISTS.

Consistent with the ISTS, the requirements regarding visual and audible count rate indications will be moved to the TS Bases. The visual and audible indication features remain installed in the plant and any future changes to the indication features will be controlled under 10 CFR 50.59.

LAR 02-0006 Page 6 ACTION The existing DBNPS LCO 3.9.2 ACTION statement reads "With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity changes. The provisions of Specification 3.0.3 are not applicable."

The corresponding ISTS section is in tabular format. CONDITION A, "One [required] source range neutron flux monitor inoperable" has two required ACTIONS, A.1 (Immediately)

"Suspend CORE ALTERNATIONS" and A.2 (Immediately) "Suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1." CONDITION B, "Two [required] source range neutron flux monitors inoperable" also has two required ACTIONS, B.1 (Immediately) "Initiate action to restore one source range neutron flux monitor to OPERABLE status" and B.2 (once per twelve hours) "Perform SR 3.9.1.1." ISTS SR 3.9.1.1 verifies that boron concentration is within the limit specified in the COLR.

It is proposed to revise the DBNPS TS ACTION statement to be similar to the ISTS ACTION statement, but continue to use the DBNPS TS format and use the Reactor Coolant System refueling boron concentration requirement specified in DBNPS LCO 3.9.1. The existing statement that "the provisions of TS 3.0.3 are not applicable" is unnecessary because TS 3.0.3 was intended for application in Modes 1 through 4, and because appropriate ACTION statements are proposed that fully address any loss of source range monitoring in MODE 6.

The existing DBNPS LCO 3.9.2 ACTION statement immediately suspends all operations involving positive reactivity changes. The proposed revision changes the requirement to suspend all positive reactivity additions to "Immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than the RCS boron concentration requirement of LCO 3.9.1." Allowing boron concentration reductions when one or more monitors is inoperable is acceptable because the ACTIONS will continue to provide assurance that the RCS boron concentration will be maintained greater than br equal to the required Reactor Coolant System refueling boron concentration. Maintaining the required boron concentration ensures stable core reactivity during refueling. Therefore, the proposed ACTIONS will ensure that the Reactor Coolant System refueling boron concentration is maintained within the assumptions of the safety analyses and that the core is maintained in a stable shutdown condition.

It is proposed to add ACTION b. I to the DBNPS TS 3.9.2, which is an administrative change to clarify that in the case where there is no OPERABLE source range neutron flux monitor, ACTION a for only one OPERABLE source range neutron flux monitor must also be performed.

This is an administrative change to add clarity to an ACTION that would be difficult to interpret after conversion from the ISTS format to the DBNPS format.

ISTS ACTION B.2 has no corresponding requirement in the existing DBNPS TS. ACTION B.2 verifies that boron concentration is within refueling limits. With no source range neutron flux monitor OPERABLE, there is no direct means of detecting changes in core reactivity. However, since CORE ALTERATIONS and positive reactivity change are prohibited, the core reactivity

LAR 02-0006 Page 7 condition is stabilized until the source range neutron flux monitors are OPERABLE. This stabilized condition will be determined by verifying in DBNPS TS ACTION b.3 that boron concentration is within the requirement specified LCO 3.9.1. The completion time of once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is sufficient to obtain and analyze a reactor coolant sample for boron concentration and ensures that unplanned changes in boron concentration would be identified. The 12-hour frequency is reasonable, considering the low probability of a change in core reactivity during this time period. Note: The corresponding ISTS specification refers to the Shutdown Margin Limits in the COLR. At the DBNPS, the corresponding refueling boron concentration is determined from the kff required by LCO 3.9.1 instead of the COLR, and this difference is reflected in the proposed change.

SURVEILLANCE REOUIREMENTS It is proposed to revise the DBNPS SRs to be similar to the ISTS SRs. As described above, this includes deletion of the independent mention of the CHANNEL FUNCTIONAL TEST.

Consistent with the ISTS, the requested change also adds the ISTS exclusion of neutron detectors from the CHANNEL CALIBRATION.

DBNPS SR 4.9.2 specifies that a CHANNEL FUNCTIONAL TEST is required for the source range neutron flux monitors at least once per 7 days and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the initial start of CORE ALTERATIONS. The corresponding ISTS Surveillance Requirements do not include performing CHANNEL FUNCTIONAL TESTS for the source range monitors. The requested change deletes these CHANNEL FUNCTIONAL TEST requirements, consistent with the ISTS.

This change is acceptable because the CHANNEL FUNCTIONAL TEST requirements are not necessary to verify that the source range neutron flux monitors are capable of satisfying the LCO requirements. In MODE 6, the source range monitors are required for indication only; there are no required setpoints associated with these instruments in MODE 6. As used in MODE 6, the source range instrumentation provides indication of significant changes in the count rate that could be due to a change in core reactivity.

Consistent with the ISTS, instrumentation used only for indication requires CHANNEL CHECKS and CHANNEL CALIBRATIONS. In the ISTS, the CHANNEL FUNCTIONAL TESTS are applied only to those instrument channels associated with required operational interlocks or actuations that have precise setpoints to be maintained within a specified accuracy over time. Consistent with the ISTS it is proposed that the CHANNEL CHECK surveillance be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> throughout MODE 6 operation instead ofjust during CORE ALTERATIONS.

This change is more restrictive than the current SR. The 18-month CHANNEL CALIBRATION and 12-hour CHANNEL CHECK surveillance requirements typically applicable for other indication-only instrumentation in the TS have proven effective in demonstrating that instrumentation is operable. Considering the more frequent CHANNEL FUNCTIONAL TEST performed on the source range monitors in other MODES, and the effectiveness of the 18-month CHANNEL CALIBRATION and 12-hour CHANNEL CHECK surveillance requirements in maintaining other indication-only instrumentation operable, the proposed MODE 6 surveillance requirements for the source range monitors are adequate to assure their continued operability during refueling operations. Thus, the source range

LAR 02-0006 Page 8 instruments will continue to be tested in a manner and at a frequency necessary to give confidence that the instrumentation is operable.

The requested change includes clarification that CHANNEL CALIBRATION excludes the neutron detectors themselves. DBNPS USAR Chapter 7 invokes Institute of Electrical and Electronics Engineers (IEEE) Standard 338-1971, IEEE Trial-Use Criteria for the Periodic Testing of Nuclear Power Generating Station Protection Systems, for determining testing requirements for protective systems. Although the source range detectors do not provide a protective function in MODE 6, IEEE Std. 338 remains a good reference as to the required scope of a TS CHANNEL CALIBRATION. IEEE Std. 338-1971 provides that it is acceptable to "introduce and (vary), as appropriate, an analog input for partial testing of a channel when complete checks, including those of the sensors, are not practical." Establishing a calibrated neutron field around the detectors would pose personnel safety and technical challenges that make calibration of the neutron detectors impractical. Not testing the neutron detectors is consistent with IEEE 338-1971, and is consistent with the ISTS, which requires testing from the pre-amplifier input to the indicators. The ISTS Bases note that "Operating experience has shown these components usually pass the Surveillance when performed at the [18] month (f)requency."

This proposed treatment of the source range neutron detectors is consistent with DBNPS TS 3/4.3.1.1, Reactor Protection System Instrumentation, Table 4.3-1, Reactor Protection System Instrumentation Surveillance Requirements, Functional Unit 11, "Source Range, Neutron Flux and Rate," which specifies a CHANNEL CALIBRATION applicable in MODES 2,3, 4, and 5.

The Table 4.3-1 CHANNEL CALIBRATION requirement is modified by Note (6), which states:

"Neutron detectors may be excluded from CHANNEL CALIBRATION."

The frequency requirement for CHANNEL CALIBRATION in ISTS 3.9.2.2 is "[18] Months."

The frequency requirement for CHANNEL CALIBRATION in DBNPS TS 4.9.2.d is "A CHANNEL CALIBRATION prior to entry into MODE 6 if not performed within the last 18 months." The DBNPS wording is retained in the proposed change, as it is felt that this provides appropriate clarification that the CHANNEL CALIBRATION must be performed prior to entry into MODE 6.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration At the Davis-Besse Nuclear Power Station (DBNPS), there are four source range neutron flux monitors, two in the Nuclear Instrumentation System and two in the Post-Accident Monitoring System.

The Nuclear Instrumentation System monitors reactivity conditions by detecting neutrons that leave the reactor core. The nuclear instruments monitor three overlapping ranges of flux: source range, intermediate range, and power range.

There are two electrically and physically independent source range channels in the Nuclear Instrumentation System. The source range instrumentation sensors

LAR 02-0006 Page 9 are high sensitivity proportional counters that monitor neutron flux over a range of I x 10.1 to 1 x 106 counts per second.

The Post-Accident Monitoring System (PAMS) also monitors reactivity conditions. Two safety grade electrically and physically independent fission chamber instrument strings are provided. The resulting signal is converted into source range (1 x 10-1 to 1 x 10 counts per second) and wide range indication.

The signal processor also provides audible indication in the main control room and in containment.

The proposed amendment would revise the Technical Specification (TS) requirements for the source range instrumentation in the Nuclear Instrumentation System and the Post-Accident Monitoring System to more closely match standard requirements found in NUREG-1430, Standard Technical Specifications -

Babcock and Wilcox Plants, otherwise known the "Improved Standard Technical Specifications" (ISTS).

The proposed changes affect TS 3/4.9.2, Refueling Operations - Instrumentation, as follows:

Limiting Condition for Operation (LCO) 3.9.2 would be revised to read "Two source range neutron flux monitors, one from each side of the reactor core, shall be OPERABLE." In addition, the LCO 3.9.2 ACTION statement would be revised to be equivalent to the ISTS ACTION statement, while continuing to use the DBNPS format and referencing the Reactor Coolant System refueling boron concentration requirement specified in DBNPS LCO 3.9.1, Refueling Operations

- Boron Concentration. The DBNPS TS 4.9.2 Surveillance Requirements (SRs) would also be revised to be equivalent to the ISTS SRs, including deletion of the independent mention of the CHANNEL FUNCTIONAL TEST.

An evaluation has been performed to determine whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The changes affect the Limiting Condition for Operation for Refueling Operations - Instrumentation, in particular, the LCO sections pertaining to the source range neutron flux detectors will be changed to be more like the corresponding sections in the Improved Standard Technical Specifications.

The source range neutron flux detectors have no control functions and are therefore not accident initiators. Consequently, the proposed changes will

LAR 02-0006 Page 10 have no impact on the probability of any accident previously evaluated.

The detectors are not credited in mitigating the consequences of any accident; therefore, the proposed changes will have no impact on the consequences of any accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The changes affect the Limiting Condition for Operation for Refueling Operations - Instrumentation, in particular, the source range neutron flux detectors. The source range neutron flux detectors will continue to operate in the same manner as previously considered. Accident initial conditions and assumptions remain as previously analyzed.

The proposed changes do not introduce any new or different accident initiators. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

3.

Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The changes affect the Limiting Condition for Operation for Refueling Operations - Instrumentation; in particular, the source range neutron detectors. These detectors have no control functions, and are not credited in mitigating the consequences of any accident. The source range neutron detectors are not associated with a safety limit. In addition, the proposed changes to TS will not result in design changes to the source range neutron detectors or in changes to how the source range detectors are used.

Therefore, the proposed change will not involve a significant reduction in a margin of safety.

Based on the above, it is concluded that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, there is a finding of "no significant hazards consideration."

5.2 Applicable Regulatorv Requirements/Criteria The requested change was based on NUREG-1430, Revision 3, Standard Technical Specifications - Babcock and Wilcox Plants.

LAR 02-0006 Page 1 1 The source range instrumentation is credited in the Davis-Besse Nuclear Power Station Updated Safety Analysis Report as an instrumentation system that meets 10 CFR 50 Appendix A, Criterion 13, "Instrumentation and Control."

Criterion 13 identifies categories of instrumentation required to monitor plant variables and systems during normal, abnormal, and accident conditions. The level of detail of the requested changes is beneath the level of detail of Criterion 13, so that there is no impact on compliance with this regulation.

No other applicable regulatory requirements were identified during preparation of this request.

In conclusion, based on the considerations discussed above, (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 the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

LAR 02-0006 Page 12

7.0 REFERENCES

1.

DBNPS Operating License NPF-3, Appendix A Technical Specifications through Amendment 262.

2.

DBNPS Updated Safety Analysis Report through Revision 24.

3.

NUREG-1430, Revision 3, Standard Technical Specifications - Babcock and Wilcox Plants.

4.

Standard, IEEE 338-1971, IEEE Trial Use Criteria for the Periodic Testing ofNuclear Power Generating Station Protection Systems.

8.0 ATTACHMENTS

1.

Proposed Mark-Up of Technical Specification Pages

2.

Proposed Retyped Technical Specification Pages

3.

Technical Specification Bases Pages

LAR 02-0006 PROPOSED MARK-UP OF TECHNICAL SPECIFICATION PAGES (2 pages follow)

INFORMATION ONLY 3/4.9 REFUELING OPEATIONS BORON CONCENTRATION LIMITING CONDITION FOR OPERATION 3.9.1 The boron concentration of all filled portions of the Reactor Coolant System and the refueling canal.,shall be maintained uniform and sufficient to ensure a Keff of 0.95 or less, which includes a 1% 6k/k conservative allowance for uncertainties.

APPLICABILITY: MODE 6.

ACTION:

With the requirements of the above specification not satisfied, immediately suspend all operations involving CORE ALTERATIONS or positive reactivity.

changes and initiate and continue boration of 2 12 gpm of 7875 ppm boric acid solution or its equivalent until Keff is reduced to

• 0.95. The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.9.1.1 The above condition shall be determined prior to:

a. Removing or unbolting the reactor vessel head, and

b. Withdrawal of any safety or regulating rod in excess of 3 feet from its fully inserted position within the reactor pressure vessel.

4.9.1.2 The boron concentration of the reactor pressure vessel and the refueling canal shall be determined by chemical analysis at least once each 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

DAVIS-BESSE, UNIT I 3/4 9-1 Amendment No. 1-43, 207

REFUELING OPERATIONS INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.9.2= As a minimum, two TJwosource range neutron flux monitors, one from each side of the reactor core, shall be a,

each ith continuous visual indication in the control room and one with audible indication in the containment and control room.

APPLICABILITY: MODE 6.

ACTION: !.tt_

With nhe re.out remenis ef tne above speeineati.n not A 415f operations involving CORE ALTERATIONS or positi provisions of Specification 3.0.3 are not applicable. a.

OPERABLE urcrezange-neutronIfluxmonitors.

led, immediately suspend all ve reactivity changes. The

--With only oenofAhe reuired

1. ImmediateJy.Suspen COREALTERATIONS, anld 2

mmediately-uspenbperaimnsLwadause-intr-Qduc-timno xanintoAhe RCS with boron cconcentratiequiremtnd LCO3.9.1

b. WithmoPERABLEiir r nxe-neutron flux~monift

1. Perform ACTION a.,and 2Ummedlatelyinitia qour mngeetronjbx Montto QPERABLE~status.and

3. Onc-efl~hQurs verif that theRCS boron mcgntrntionedsthe-uirement-f LCO 3.9.1. usinzghumiclnalyais-to elcminc theboron c-onc lerac1r psure vessel anndaeln laL SURVEILLANCE.REQUIREMENTS 4.9.2 As a minimum, two source range neutron flux monitors, one from each side of the reactor core, shall be demonstrated OPERABLE by performance of:

a. A CHIANNEL UNGCT40NAL TEST at l :and onee per 7 days, andDelded I

b. A CHANNEL FUNC ONAL TEST within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> prior to the initial staS of CO_

ALTERAkTIONS, andDeleted

c. A CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS.and.

d. A CHANNEL CALIBRATION prior to entry into MODE 6 if not performed within the last 18 months.-N-c-utmn ete t5r~r edefrom CHANNEL CALIBRATION.

I DAVIS-BESSE, UNIT I 3/4 9-2 Amendment No. 172,

LAR 02-0006 PROPOSED RETYPED TECHNICAL SPECIFICATION PAGE (1 page follows)

REFUELING OPERATIONS INSTRUMENTATION MJTIIKG-CONDITION FQOR OPERATION 3.9.2 Two source range neutron flux monitors, one from each side of the reactor core, shall be OPERABLE.

APPLICABILITY: MODE 6.

ACTION:

a. With only one of the required OPERABLE source range neutron flux monitors,

1. Immediately suspend CORE ALTERATIONS, and

2. Immediately suspend operations that would cause introduction of coolant into the RCS with boron concentration less than the RCS boron concentration requirement of LCO 3.9.1.

b. With no OPERABLE source range neutron flux monitor,

1. Perform ACTION a., and

2. Immediately initiate action to restore one source range neutron flux monitor to OPERABLE status, and

3. Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> verify that the RCS boron concentration meets the requirement of LCO 3.9.1, using chemical analysis to determine the boron concentration of the reactor pressure vessel and the refueling canal.

SURVEILLANCEREQUIREMENTS 4.9.2 As a minimum, two source range neutron flux monitors, one from each side of the reactor core, shall be demonstrated OPERABLE by performance of:

a. Deleted

b. Deleted

c. A CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, and

d. A CHANNEL CALIBRATION prior to entry into MODE 6 if not performed within the last 18 months. Neutron detectors are excluded from CHANNEL CALIBRATION.

DAVIS-BESSE, UNIT I 3/4 9-2 Amendment No. 172,

LAR 02-0006 TECHNICAL SPECIFICATION BASES PAGES (2 pages follow)

Note: TEe Bases pages are provided for information only.

INFORMATION ONLY 3/4.9 REFUELING OPERATIONS 3ASES 3/4.9.1 BORON CONCENTRATION The limitation on reactivity during REFUELING ensures that: 1) the reactor will remain subcritical during CORE ALTERATIONS, and 2) a uniform boron concentration is maintained for reactivity control in the water volumes having direct access to the reactor vessel. This limitation is consistent with the initial conditions assumed for the boron dilution incident in the accident analysis.

The ACTION statement's minimum boration flow rate of 12 gpm is less than the minimum boration flow rate of 25 gpm specified in TS 3/4.1.1.1, Reactivity Control - Shutdown Margin because the lower flow rate is based on only borating the reactor vessel.

3/4.9.2 INSTRUMENTATION The OPERABILITY of source range neutron flux monitors ensures that redundant monitoring capability is available to detect changes in the reactivity condition of the core.-The monitorsPxoadecontinuos-visualndicatiorLinAhe-contr-ot oom,-andrLne-canneI audible-indiction conainmenandjn-the cntrQlmm 3/4.9.3 DECAY TIME The minimum requirement for reactor subcriticality prior to movement of irradiated fuel assemblies in the reactor pressure vessel ensures that sufficient time has elapsed to allow the radioactive decay of the short lived fission products. This decay time is consistent with the assumptions used in the safety analyses.

3/4.9.4 CONTAINMENT PENETRATIONS During CORE ALTERATIONS or movement of irradiated fuel within the containment, release of fission product radioactivity to the environment as a result of a fuel element rupture must be minimized. During MODES 1, 2, 3, and 4, this is accomplished by maintaining CONTAINMENT INTEGRITY as described in LCO 3.6.1.1. In other situations, the potential for containment pressurization as a result of an accident is not present, and therefore less stringent requirements are needed to isolate the containment from the atmosphere outside containment.

Both containment personnel air lock doors may be open during CORE ALTERATIONS or during movement of irradiated fuel within the containment provided the conditions specified in LCO 3.9.4.b are met. The individual designated to be continuously available to close the air lock door must be stationed at the auxiliary building side of the air lock. A containment personnel air lock door is considered capable of being closed if the door is not blocked in such a way that it cannot be expeditiously closed, and any hoses and cables running through the airlock employ a means to allow safe, quick disconnect or severance, and are tagged at the airlock with specific instructions to expedite removal. The LCO 3.9.10 requirement to maintain a minimum of 23 feet of water over the top of irradiated fuel assemblies seated within the reactor pressure vessel during movement of fuel assemblies within the reactor pressure vessel while in MODE 6 ensures DAVIS-BESSE, UNIT 1 B 3/4 9-1 Amendment 186, 202, 207, Revised by NRC letter dated March 19, 1998

REFUELING OPERATIONS INFORMATION ONLY 3SAES 3/4.9.4 CONTAINMENT PENETRATIONS (Continued) that sufficient water depth is available to remove 99% of the assumed iodine gap activity released from the rupture of an irradiated fuel assembly. Further, sufficient time is available to close the personnel air lock following a loss of shutdown cooling before boiling occurs.

Regarding LCO 3.9.4.c, the phrase "atmosphere outside containment" refers to anywhere outside the containment vessel, including (but not limited to) the containment annulus and the auxiliary building.

The containment equipment hatch cover may be off during CORE ALTERATIONS or movement of irradiated fuel in containment provided the requirements of Specification 3.9.12 are satisfied. The requirements of Specification 3.9.12 ensure that the emergency ventilation system servicing the storage area is OPERABLE with the ability to filter any radioactive release through the containment equipment hatch following a fuel handling accident. Since containment closure is not credited for mitigating the consequences of the fuel handling accident as described in the Updated Safety Analysis Report, the equipment hatch cover need not be installed to ensure adequate protection of the public health or safety.

For penetrations that are closed by a method equivalent to a manual or automatic isolation valve, or a blind flange, the isolation technique must be approved by an engineering evaluation. The isolation technique may include the use of a material that can provide a temporary seal capable of maintaining the integrity of the penetration to restrict the release of radioactive material from a fuel handling accident.

With the containment purge and exhaust system in operation, a high radiation signal received from the containment purge and exhaust system noble gas monitor will effectively automatically contain the release by shutting down the containment purge system supply and exhaust fans and closing their inlet and outlet dampers. On a valid signal, the control room operator will then manually close the containment purge and exhaust isolation valves. Therefore, the uncontrolled release of radioactive material from the containment to the environment wvill be restricted.

With the containment purge and exhaust system not in operation, there would be no flow to the containment purge and exhaust system noble gas monitor, hence the requirements of Specification 3.9.4.c.2 would not be satisfied. In this situation, unless Specification 3.9.4.c.1 is satisfied, entry into the Action statement would be required.

With a containment purge penetration not capable of being closed from the control room by an OPERABLE containment purge and exhaust isolation valve upon receipt of a high radiation signal from the containment purge and exhaust system noble gas monitor, closure of the containment purge and exhaust penetrations with at least one isolation valve ensures that the uncontrolled release of radioactive material from the containment to the environment will be restricted.

3/4.9.5 COMMUNICATIONS DELETED DAVIS-BESSE, UNIT I B 3/4 9-1la Amendment No. 186, 202, 221, 224, 251,

Docket Number 50-346 License Number NPF-3 Serial Number 3093 COMMITMENT LIST THE FOLLOWING LIST IDENTIFIES THOSE ACTIONS COMMITTED TO BY THE DAVIS-BESSE NUCLEAR POWER STATION (DBNPS) IN THIS DOCUMENT. ANY OTHER ACTIONS DISCUSSED IN THE SUBMITTAL REPRESENT INTENDED OR PLANNED ACTIONS BY THE DBNPS. THEY ARE DESCRIBED ONLY FOR INFORMATION AND ARE NOT REGULATORY COMMITMENTS. PLEASE NOTIFY THE SUPERVISOR - FLEET LICENSING (330-315-6944) OF ANY QUESTIONS REGARDING THIS DOCUMENT OR ANY ASSOCIATED REGULATORY COMMITMENTS.

COMMITMENTS DUE DATE Associated changes to the TS Bases would be made Concurrent with under the provisions of the TS Bases Control Program.

implementation of These changes are expected to include additional detail, LAR 02-0006.

including a discussion of the visual and audible indication features formerly referenced in the LCO.