L-08-159, Supplement to License Amendment Request: Conversion of Current Technical Specifications (CTS) to Improved Technical Specifications (ITS) - Volumes 5, 6, 7, 9, 11, and 15, TAC No. MD6398

Supplement to License Amendment Request: Conversion of Current Technical Specifications (CTS) to Improved Technical Specifications (ITS) - Volumes 5, 6, 7, 9, 11, and 15, TAC No. MD6398

ML081480464
Person / Time
Site:	Davis Besse
Issue date:	05/16/2008
From:	Allen B FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-159, TAC MD6398
Download: ML081480464 (5)

Text

FENOC FE O 5501 North State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449 Barry S. Allen 419-321-7676 Vice President - Nuclear Fax: 419-321-7582 May 16, 2008 L-08-159 10 CFR 50.90 ATTN: Document Control Desk United States Nuclear Regulatory Commission Washington, D. C. 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit 1 Docket No. 50-346, License No. NPF-3 Supplement to License Amendment Request: Conversion of Current Technical Specifications (CTS) to Improved Technical Specifications (ITS) - Volumes 5, 6, 7, 9, 11, and 15, TAC No. MD6398 By letter dated August 3, 2007, FirstEnergy Nuclear Operatingd Cbompany (FENOC) submitted an application to amend the Technical Specifications of Davis-Besse.Nuclear Power Station, Unit 1 (DBNPS), revising the current Technical Specifications (CTS) to the Improved Technical Specifications (ITS) consistent with the Improved Standard Technical Specifications (ISTS) as described in NUREG-1430, "Standard Technical Specifications Babcock and Wilcox Plants," Revision 3.1, and certain generic changes to the NUREG.

The purpose of this letter is to supplement that original license amendment request as a result of responses to U.S. Nuclear Regulatory Commission (NRC) questions as documented on the NRC and FENOC Davis-Besse ITS Conversion Website. The guidance of Nuclear Energy Institute (NEI) 96-06, "Improved Technical Specifications Conversion Guidance," dated August 1996, and Nuclear Regulatory Commission (NRC)

Administrative Letter 96-04, "Efficient Adoption of Improved Standard Technical Specifications," dated October 9, 1996, were used in preparing this supplement to the original ITS submittal. This letter provides the supplement for the following Attachment 1 Volumes only:

Volume 5, Section 3.0 - LCO [Limiting Condition for Operation] and SR [Surveillance Requirement] Applicability, Revision 1; Volume 6, Section 3.1 - Reactivity Control Systems, Revision 1; Volume 7, Section 3.2 - Power Distribution Limits, Revision 1; Volume 9, Section 3.4 - Reactor Coolant System (RCS), Revision 1; Volume 11, Section 3.6 - Containment Systems, Revision 1; and Volume 15, Chapter 4.0 - Design Features, Revision 1.

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Davis-Besse Nuclear Power Station L-08-159 Page 2 of 2 Supplements for the remaining Volumes will be provided in a future submittal.

Each Volume in the Attachment includes a Summary of Changes page at the beginning of the Volume. This Summary of Changes page identifies all changes made to the previous submittal (Revision 0). This includes a brief description of the change and the affected page numbers in the Revision 1 Volume. In addition, the affected Revision 1 pages have a revision bar to the right of the change to aid in identification of the change. Furthermore, one self-identified change, which was discussed in RAI 200710031426, has not been included in Volume 7, Section 3.2. Davis-Besse has re-evaluated the requested draft change and has decided the change is not necessary.

The detailed descriptions and justifications to support the proposed changes are provided in the Attachment 1 to this letter. FENOC has evaluated this proposed change in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92(c), and has concluded that the determination of no significant hazards considerations for the original ITS submittal remains valid. In addition, FENOC has determined that the proposed license amendment, including this supplement to the original ITS submittal, continues to meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(b), and no environmental impact statement or environmental assessmentý.need be prepared in connection with the proposed license amendment. The specific determination of no significant hazards considerations are included in Attachment 1 and the generic determination of no significant hazards consideration and environmental assessment were previously submitted by letter dated August 3, 2007 (Attachment 1, Volume 2) and any future changes to these generic assessments will be included in a future submittal.

The commitments are listed in Attachment 2. The attachment includes the previous commitments provided in the letter dated August 3, 2007 (commitments 1 and 2) and are included in this Attachment for your convenience and the new commitment contained in this letter (commitment 3).

If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 761-6071.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 14A

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.i66 Sincerely, Barry S lnVice President-Nuclear

Davis-Besse Nuclear Power Station L-08-159 Page 3 of 3 Attachments: 1. ITS Submittal, Volumes 5, 6, 7, 9, 11, and 15

2. Commitment List cc:

(all w/o Attachment 1)

NRC Region III Administrator NRR Project Manager NRC Resident Inspector Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board L-08-159 Commitments List Page 1 of 2 The following list identifies those actions committed to by FirstEnergy Nuclear Operating Company (FENOC) for 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 as information and are not Regulatory Commitments. Please notify Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 761-6071 of any questions regarding this document or associated Regulatory Commitments.

Regulatory Commitment Due Date

1. FENOC will notify the NRC when ITS implementation

1. Following actions are completed.

implementation of the approved license amendment.

2. The following guidelines will be included in the assessment of systems removed from service during movement of irradiated fuel:

During fuel handling/core alterations, ventilation system and radiation monitor availability (as defined in NUMARC 91-06) should be assessed, with respect to filtration and monitoring of releases from the fuel. Following shutdown, radioactivity in the fuel decays away fairly rapidly. The basis of the Technical Specification operability amendment is the reduction in doses due to such decay. The goal of maintaining ventilation system and radiation monitor availability is to reduce doses even further below that provided by the natural decay.

A single normal or contingency method to promptly close primary or secondary containment penetrations should be developed. Such prompt methods need not completely block the penetration or be capable of resisting pressure.

The purpose of the "prompt methods" mentioned above are to enable ventilation systems to draw the release from a postulated fuel handling accident in the proper direction such that it can be treated and monitored.

[Reference NUREG-1430 Bases 3.9.3 Reviewer's Note regarding the term "recently" associated with handling irradiated fuel, consistent with NUMARC 93-01, Revision 4, Section 11.3.6.5.]

2. Upon implementation of the approved license amendment.

L-08-159 Page 2 of 2

3. Davis-Besse will ensure appropriate plant procedures and administrative controls will be used to implement the applicable Tier 2 Restrictions when LCO 3.0.8 is used. Specifically: a) at least one EFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s) must be available when LCO 3.0.8.a is used; b) at least one EFW train (including a minimum set of supporting equipment required for its successful operation) not associated with the inoperable snubber(s), or some alternative means of core cooling must be available when LCO 3.0.8.b is used; and c) every time the provisions of LCO 3.0.8 are used, Davis-Besse will confirm that at least one train of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads.

In addition, a record of the design function of the inoperable snubber (i.e., seismic vs. non-seismic),

implementation of any applicable Tier 2 restrictions, and the associated plant configuration shall be available on a recoverable basis for NRC staff inspection.

3. Upon implementation of the approved license amendment.