ML19225C616

Forwards Application for Amend to License NPF-3 Re Extension of Time to Perform First Inservice Insp of Steam Generator Tubes & Revised Steam Generator Tube Sampling Selection

ML19225C616
Person / Time
Site:	Davis Besse
Issue date:	07/27/1979
From:	Roe L TOLEDO EDISON CO.
To:	Reid R Office of Nuclear Reactor Regulation
References
NUDOCS 7908010361
Download: ML19225C616 (9)

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Docket 30. 50 '46 . j b TCLE00 Licease No. NPF-3  % EDISON Serial No. 329 0s . E ACE a

July 27, 1979 '.<."~"." c . ". e , n i4*91 2"9 5249 Director of Nuclea- Reactor Regulati~.'

Attention: Mr. Robert N. Reid, Chief Operating Reactors Branch No. 4 Division of Operating Reactors United States Nucl;ar Regulatory Commission k'ashington, D. C. 20555

Dear Mr. Reid:

Under separate cover, we are transmitting threa (1) original and forty (40) conformed copies of an application for Amendment to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station Unit No. 1 This application requests that the Davis-Besse Nuclear Power Station Unit 1 Technical Specification, Appendix A, be revised. The proposed change includes alterations in section 4.4.5 to provide: 1) an extension of calendar time to preform the first in-service inspections of steam generator tubes af ter initial criticality in sub-section 4.4.5.3; and 21 revised steam generator tube sampling selection in sub-section 4.4.5.2.

This e Ament request involves a Class III type issue. Therefore, $4,000 is enclo as required by 10CFR170.

The two attachments identify each section of the proposed change, its safety evaluation and schedule required to implenent the chang- after NRC approval. .our attentien is particularly directed to Attachment I concerning steam generator tube inspection schedules. As we have discussed with four staff we request your final accion on this prior to August 12, 1979.

Yours very t rt ly,

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THE TCLECO ECISCN CCMPANY EC SON PLAZA 300 MAClSCN AVENUE TCLECO. CH:0 43552

APPLICATION FOR AMENDMENT TO FACILlTY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Enclosed >are forty-three (43) copies of the requested changes to the Davis-Besse Nuclear Power Station Unit No. 1 Technical Specifications, Appendix A to Facility Operating License No. NPF-3, together with the Safety Evaluation for the requested change. The proposed changes include alterations in'section 4.4.5 to provide: 1) an extension of calendar time to preform'the first inservice inspection of steam generator tubes after initial criticality in sub-section 4.4.5.3; and 2) revised steam generator tube sampling selection in sub-section 4.4.5.2.

By s/Lowell E. Roe Vice President, Facilities Development Sworn to and subscribed before me this twenty-seventh day of July, 1979.

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Notary Public LINDA L. COSTELL flotary PuMC - State of Ch a f.iy Commission Expires reb 9,1932 443 338

Docket No. 50-346 License No. NPF-3 Serial No. 529 July 27, 1979 I. Change to Davis-Besse Nuclear Power Station, Unit No. 1 (DB-1) Technical Specifications, Appendix A of section 4.4.S.3 to allow the first steam generator tube inservice inspeccion to bc preformed during the first refueling outage. - See proposed change attached.

A. Time Required to Implement This change can be effective upon NRC issuance.

B. Reason for change (Facility Change Request 78-258)

Due to the extended outages Davis-Besse Unit I has had since initial criticality, the first refu3 ling outage has been delayed until March, 19 80. T;te first steam generator tube inservice inspection was expected to be done during that outage. The current refueling outage schedule would not coincide with the 24 calendar months stated in section L.4.5.3.

C. Safei aluation see attached 443 339

Docket No. 50-346 License No. NPF-3 Serial No. 529 July 27, 1979

'PEACTOR CC0LANT $YSTEM f 5'2.'EILLANCE REC'jIRE"ENTS (Continued)

Note: In all inspections, previously degraded tubes murt exhibit significant (> 10S) furtner wall ;enetraticns to be included in the above percentage calcul&: ions.

a.4.5.3 Inscection Frecuene'es - The above recuired inservice ins ections of steam generator tubes snall be performed at the following frecuenc.es-

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-- - .. j, Subsequent inservice inspections shall be l performed at intervals of not less than 12 nor more than 22 calendar months after the previous insoection. If two consecu-tive inscections following service under AVT conditions, not including the preservice inspection, result in all ins:ection results falling into the C-1 category or if two consecutive 9

inspections demonstrate that previously observed degradaticn has not continued and no additional degradation has occurred, the insoection interval may be extended to a maximum of once per 40 conths.

b. If the results of the inservice inspection cf a steam generator conducted in accordance with Table 4.a-2 at 40 month ir.tervais fall into Category C-3, thc inspect'nn frequency sr.all ba increased to at least once per 20 months. The increase in inspection frequency shall aoply until the subs.quent inscections satisfy the criteria of Specification 4.4.5.3.a, the interval may then be extended to a maximum of once per JO Tonths.

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c. Adci ti:nal, ;nscneduled inservice ir,spections shal' ce cecfccmed i on each steam generator in accordance with tne first sarole inspection scecified in Table 4.2-2 during the shutccwn su: sequent to any of the following conditions:

1. Primary-to-secondary tubes leaks (not including leass originating frca tube-to tube sheet welds) in excess of t.ie limits of Speci1ica. tion 3.4.5.2.

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2. A seismic v currence greater tnan the Operating Sasis Earthquake,

a. A loss-of-coolant accident recuiring actuation of tne engineered safeguards.

4. A main steam line or feedwater line break.4 4 3 340 Dr.;IS-BESSE, UNIT 1 3/4 4-8 .

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Docket No. 50-346 License 50. NIF-3 Serial No. 329 July 27, 1979 q

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The Davis-Eesse Nuclear Power Station in-service inspection (ISI) fre-qLenc; Technical Specifica:ica, Appendia. A, Section, Para. .L.5.3 presently requires that the first 151 of the steam generator tubes be performed af ter 6 ef f ective full-pcwer =cnths but within21 conths of initial criticality (3/12/77). The currently scheduled first refueling outage is scheduled for March 1980. The first ISI of the stea generator tubes is scheduled to be perforced during the March 1930 outaga. Tre rese2:s of the tube inspection will be succitted to the NRC as per Tecnnical Specification ,.4.5.5. Thus, it is desired that the ti;.a limit of Technical Specification 4.4.5.3 be extended to allow for the steam generator tube ISI to coincide with the first refueling cutage.

The 6 effective full-power =cnchs but with.D1 24 onths of initial criti-

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cality was based on the projected operating schedula for Davis-3 esse at the time the operating license was issued.

Davis-3 esse is r9 questing relief from this schedule due to the first regularly scheduled refueling outage will be later than originally planned.

The additienel time requested prior to the stea generator tube ISI does not add significant probability of tube failure.

The Davis-Besse Nuclear Power Station Technical Specifica icus (3/4.4.5) notes, the program for ISI of the steam generator tubes is based on a

=odification of US NRC Regulatory Guide 1.83, Revision 1. Therefore, justification for this request appears below:

1. As referenced in US SRC Regulatory Guide 1.83, Revision 1, "!nservice Inspection of Pressurized Water Reactor Steam Generator Tubes",

paragraph c(6)(c) which states:

" Inspections =3y be made coincident with refueling cutages or any shutdcwn for plant repair and cain:enance in accordance with the A=erican Society of Mev: Inical Engineers Boiler and Pressure Vessel Ccde,Section II."

2. That the inteac of Sectica XI is to provide a techanism for the direction of an inspection based on onerating time of the pcwer facility.

Paragraph IWA-2400(a) of the 1974 Section XI with addenda through Su==er 1975 states:

"....These inspections intervals represent calendar years after the reactor facility has been placed into cc==ercial service. The interval may bc extended by as much as one year to permit inspections to be concurrent with plant outages."

443 341

Docket No. 5 0- 3 '+ 6

' License No. NP F- 3 Serial No. 329 July 27, 1979 Due to the fact that Da.is-3 esse has underter.a a number of cutages since initial critical'. cn August 12, 1977, the reactor w:.ll aave not operated

+1tb any 20ditional burnup than eas originally planned by the present

'! arch 1930 refueling,cain cutages when Davis-3 esse cas .ct in operating

=cdes include: frc: 4/29/73 to 7/27/78 (2 =onths 2S days - S7 Effective Full-?cwer Days (EF?Ds)) due to the removal of the Burnable Poison ?,cd Assemblies (3PRAs) and fro: 3/29/79 to present (approx. 3 cenths 6 days - 211 EFPDs) due to SRC order in conjuaction with events at TM1-2.

Tre EFFDs (Effective Full-Power Days) for the 24 =caths after initial criticality equals approxicately 433.

Additicnal cutages in which the station was not in operating =cdes ;eere :

10/9/78 through 10/27/78 for repair of Reactor Coolant Pump Seals (18 days), 12/16/78 through 1/1/79 for repair of extraction stea: line bellows in secondary syste: (16 days) and 1/4/79 through 1/3/79 ;r Repair of Reactor Coolant Pump Seals (15 days).

Since the intent of Regulatory Guide 1.83, Revision 1, and of the ASSE Code is to provide f or inspections based on operating time of equipment, it is requested that the outage time of 7 conths and 22 days be added to our 24 conth interval to provide for an allowed inspection interval for the stea: generator tubes.

As of July 4, 1979, including the cutages fro: the BP Us, the repair to the reactor coolant pump seals and the NRC order in lieu of TM1-2, Davis-Eesse has had 211 EFPDs. Therefore, the frequency for the stea:

generator tube ISl could be extended to March 19SO to coincide with the scheduled refueling outage.

Fcr the above reasons, this is not to be determined an unreviewed safety question.

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Dacket No. 50-346 License No. NPF-3 Serial No. 529 July 27, 1979 II. Change to Davis-Besse Nuclear Power Station, Unit Nq. 1 Technical Specifi-cations, Appendix A, section 4.4.5.2.a concerning sampling of steam generator tubes for inspectione.

A. Time Required to Implement This change can be effective upon NRC issuance B. Reason for Change (Facility Change Request 79-195)

To provide inspection of all tubes in critical areas without affecting sample size and aduitional sampling criteria of non-critical areas.

C. Safety Evaluation See Attached 443 343

Docket No. 50-346 License No. NPF-3 cie r ia l No . 529 PkkTLk'CddLINT SYSTEM J r

STEAM GE:" RATCRS N LIMITING CCNDITION FOR OPERATION 3.4.5 Each steam generator shall be OPERABLE with a water level between 13 and 343 inches.

ADPLICABILITY: MODES 1. 2, 3 and 4.

ACTICN:

a. With one or more steam generators inoperable due to steam generator tube imperfections, restore the inoperable generator (s) to OPERABLE status prior .to increasing T gyg above 200 F.

b. Witn one or more : team generators incperable due to the water level being outside tb. limits, be in at least HOT STANDBY within 6. hours and in C1LD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

SURVEILLANCE RECUIREMENTS

.4.5.0 Each steam generator shall be demonstrated OPERABLE by performance of the following augmented inservice inspection program and the requirements of Specification 4.0.5.

4.4.5 1, Steam Generator Sarrole Selection and Inspection - Each steam generator shall be determin?d OPERABLE during shutdown by selecting and inspecting at least the minimum number of steam generators specified in Table 4.4-1.

1.4.5.2 Steam Generator Tube Sample Selection and Inspection - The steam ,

pnemtor tune mini .n srple size, 'nspection result classification, and *.he corresponding action required shall be as specified in Table 4.a-2. 1 The inservice inspection of steam generator tubes shall be performed at the frequencies specified in Specification 4.4.5.3 and the inspected tubes shall 3e verified acceptable per tne acceptance criteria of Specificction :.4.5.4.

The tubes selected for each inservice inspection shall include at least 35 f the total number of tubes in all steam generators; the tubes selected for these inspections shall be selected or, a random basis except:

1. Where experience in similar plants with similar water chemistry indicates critical areas to be inspected, then ' ' . .:' r:^

" c t i. : ": pct:d ;": bc # c- *':s: :"t t ' : m:.an 3dfi M &l S am p i.'^ s kall be perfved AM rAdl inc_lude au of %e ebe k %e. criMcal ave 31 hgeacled eact &fe4q

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Docket No. 50-346

- License No. NP F- 3 ~

Serial No. 529 July 27, 1979 SAFETY EVALFATION The results of steam generator tube inspections at other B&J 177 FA nlants have tcentified certa critical areas in the steam generators (such as n ' c n;; the open lane) which have a higher incidence of degraded and defective tubes. 364 recc= ends that all of the tubes in these critical areas be inspected. The remaining tubes in the steam generators have ha; a very Icw incidence of degraded and defective tubes. Detection of degraded ar.d/or

' :fective tubes in the critical ateas could require additional inspections in non-critical areas if the crit _ cia presently in the technical specifica-tion are used. These additional inspections in the non-critical areas should not be required if the results of the initial 3"'. inspection of these non-critical areas do not meet the additional sampling criteria.

The proposed technical specification change will result in inspection 100% of the critical areas, with the remaining areas of the steam generocor being insp.ected to the 37. sampling. plan and its attendant additional sampling shere degrided and/cr defective tubes are detected.

The frequency of inspections will still be determined by the inspection results on all of.the tubes. This is warranted by the need to inspect the critical areas at the frequency presently specified.

A review of U. S. Regulatory Guide 1.83 indicates that this change is .ithin compliance with that guide; and a review of the 1977 edition of the ASMI 3&?V Code Section XI indicates that this change is within compliance with that code.

{wf ll George Hurrell 5

5/11/79

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