ML20041C660

Application for Amend to License NPF-3 Consisting of Changes to Tech Specs Re one-time Extensions in Surveillance Period to Be Consistent W/Refueling Outage Start Date of 820319

ML20041C660
Person / Time
Site:	Davis Besse
Issue date:	02/23/1982
From:	Crouse R TOLEDO EDISON CO.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20041C661	List: ML20041C660 ML20041C663
References
785, TAC-47999, NUDOCS 8203020437
Download: ML20041C660 (8)

Text

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TOLEDO

% EDISON A cHAno P. CROUSE We Present NAler Docket No. 50-346 m $ 2 m 22' License No. NPF-3 Serial No. 785 \

February 23, 1982 Y n S

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Director of Nuclear Reactor Regulation Y,*o '

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Attention: Mr. John F. Stolz Operating Reactor Branch No. 4 A

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Division of Operating Reactors /

United States Nuclear Regulatory Commission V ID \ s /

Washington, D. C. 20555

Dear Mr. Stolz:

Under separate cover, we are transmitting three (3) 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 Specifications, Appendix A, be revised to reflect the changes attached. All the proposed changes involve one time extensions in the surveillance period to se consistent with a refueling outage start date of March 19, 1982. These extensions will allow more pre-outage work required to complete the large number of TMI-required modifications during the refueling period. Specifically, these changes include:

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Tables: 4.3-1, 4.3-2, and 4.3-11

[o o I I' r Sections: 4.6.4.2.b, 4.6.5.1.d and 4.7.1.2.d.

II The proposed changes and its safety evaluation are attached. The changes l concern the eighteen (18) month surveillance test for Reactor Protection [s.h ,'

l System, Safety Features Actuation System, Steam and Feedwater Rupture Control System, Containment Recirculation System, Auxiliary Feed Pump / yooo.oe Speed Switch and Emergency Ventilation System. The relief is requested only for those curveillance requirements (18 month) which are due in March 1982. Toledo Edison feels an extension of 3.2% above the current maximum allowed for the surveillance requirement in the Technical Specifications will not have an adverse effect on the public health and safety.

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8203020437 820223 PDR ADOCK 05000346 P PDR THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652

Docket No. 50-346 -

License No. NPF-3 Serial No. 785 February 23, 1982 Page 2 This amendment request involves a change of Class III type. Enclosed is a check for $4,000.00 as requested by 10 CFR 170.22. We request an expeditious review such that these can be approved by March 1, 1982.

Please contact us for any assistance.

Very truly yours,

(( 11 RPC: GAB: lab b/2 Attachment cc: DB-1 NRC Resident Inspector

APPLICATION FOR AMENDMENT TO FACILITY 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 Facility Operating License No. NPF-3, together with the Safety Evalution for thd requested change.

The proposed changes include:

Tables: 4.3-1, 4.3-2, and 4.3-11 Sections. 4.6.4.2.b, 4.6.5.1.d and 4.7.1.2.d.

By R. P. Crouse Vice President, Nuclear Sworn and subscribed before me this twenty-third day of February, 1982.

Notary Public

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LAURIE A. BRUDZINSKI Notary Public. State of Ohio My Commission Egires May 16.1986

Docket No. 50-346' -

License No. NPF-3 Serial No. 785 Februa ry 23, 1982.

Attachment I. Changes to Davis-Besse Nuclear Power Station Unit 1, Appendix A Technical Specifications Tables: 4.3-1, 4.3-2, and 4.3-11 Sections: 4.6.4.2.b, 4.6.5.1.d. and 4.7.1.2.d.

A. Time required to Implement. This change is to be effective upon NRC approval. i B. Reason for Change (Facility Change Request (82-020). To allow 4 Davis-Besse Unit No. I to operate through March 1982 with 4

exceptions to certain eighteen (18) month surveillance requirements.

i C. Safety Evaluation See attached t

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SAFETY EVALUATION This Safety Evaluation-is to allow the continued operation of Davis-Besse Unit No. I until the end of March 1982 by delaying certain eighteen (18) month surveillance testing requirements. The affected surveillance tests can be divided into six (6) general groups: _

1. Reactor Protection System (RPS) - Table 4.3-1.

2. Safety Features Actuation System (SEAS) - Table 4.3-2

3. Steam and Feedwater Rupture Control System (SFRCS) - Table 4.3-11.

4. Auxiliary Feedwater System - Section 4.7.1.2.d.

5. Containment Recirculation System - Section 4.6.4.2.b.

6. Emergency Ventilation System - Section 4.6.5.1.d.

i' The following is the Safety Function and Evaluation for each of the above items.

1. Reactor Protection System (RPS) 1 The safety function of the RPS is to protect the reactor core from Departure from Nucleate Boiling (DNB) and to prevent overpressurization of the Reactor Coolant System (RCS).

Monthly testing of the RPS is designed to assure proper actuation of the system safety function. Eighteen (18) month l calibration tests are conducted on this system to assure that the system performs its safety function within the limits l established by the accident analysis. RCS flow input instruments are used in the RPS to protect against DNB and RCS pressure instruments are used to provide RCS overpressure j protection.

Monthly testing of these instruments checks the calibration of all instruments except for the RCS flow transmitters and RCS pressure transmitters. Monthly testing does not check RPS response times. However, no system modifications have been made that would adversely affect the system response time. Also previous 18-month calibration and response time checks on these 4

flow and pressure transmitters have not indicated that these f

transmitters drift excessively. Therefore, this is not an unreviewed safety question.

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2. Safety Features Actuation System (SFAS)

The safety functions of the SFAS are to: initiate the Emergency Core Cooling System (ECCS), initiate containment isolation, initiate containment cooling and start any required support systems for the ECCS, Containment Cooling and Containment Isolation.

The portion of the SFAS where the surveillance period is to be extended is the Containment Radiation Monitor input to the SFAS.

The trip setpoint and ft 1ctional operation of the containment radiation output module is checked on a monthly basis and, if found to be outside the acceptable band, recalibrated. Previous calibration checks of the detectors has shown no signs of excessive drift. As a result of the performance of the monthly test, the risk of system malfunction due to delay of the specific 18-month calibration tests of the containment radiation monitors will not increase the risk to the health and safety of the public.

Therefore, this is not an unreviewed safety question.

3. Steam and Feedwater Rupture Control System (SFRCS)

The safety function of the SFRCS is to provide feedwater to the steam generators on a loss of main feedwater for secondary side heat removal and to initiate and promote RCS natural cirulation in the event of a loss of forced circulation.

The monthly testing of the SFRCS is designed to ensure proper functioning of all the inputs of the system. During this functional testing, calibration of all transmitters (except the steam generator level transmitters) and associated bistables is verified. If performance of the monthly tests reveal instrument operation and/or setpoint outside the acceptable band, maintenance is performed to restore this operation /setpoint within limits. Toledo Edison has verified successful operation of SFRCS through both a manual actuation on June 24, 1981 and a low steam generator level on October 16, 1981. These events duplicate the SFRCS refueling test, and verify the performance of the steam generator level transmitters. As a result of the above, the successful monthly testing and the fact that no instrumentation modifications have been implemer.ted, (since the successful performance of the last 18-month calibration check),

the requested extension of the surveillance period for response time testing, the integrated SFRCS testing and the calibration of steam generator level transmitters to input to SFRCS will not increase the threat to the health and safety of the public.

Therefore, this is not an unreviewed safety question.

4. Auxiliary Feedwater System (AFW)

The Safety Function of the Auxiliary Feedwater System is to provide feedwater to the steam generators on a loss of main feedwater for secondary side heat removal and to initiate and promote RCS natural cirulation in the event of a loss of forced circulation.

t A monthly test of the speed switch is performed to verify the operability of the switch. Based on several successful performances of this test in the past and because the speed switch calibration is the only portion of the 18-month test to be delayed and the opera'oi]ity of the switch is verified each month, we feel there is no increased risk to the health and safety of the public. Therefore, this is not an unreviewed safety question.

5. Containment Recirculation System The Safety Function of the Containment Recirculation System (as

, part of the combustible gas control system) is to maintain the maximum hydrogen concentration within the containment vessel at or below three volume percent following a LOCA.

The Evaluation for the Containment Recirculation System 18-month surveillance test verifies that the fans start, run acceptablly and generate an appropriate flow rate. Past performance of the test shows that both fans generate more than the minimum acceptable flow rate. Also, it is current operating practice to run or.e of the redundant fans at all times.

, Based upon past test results and current operating practice, it

is concluded that delaying the performance of the Containment Recirculation System 18-month test will not increase the risk to the health and safety of the public. Therefore, this is not an unreviewed safety question.

6. Emergency Ventilation System (EVS)

The Safety Function of the EVS ensures that containment vessel leakage occurring during LOCA conditions into the annulus will be filtered through the HEPA filters and charcoal absorber-trains prior tc discharge to the atmosphere. This requirement is necessary to meet the assumptions used in the safety analyses and limit the site boundary radiation dose to within the limits of 10CFR 100 during LOCA.

The 18-month surveillance test for the EVS required in March

, 1982 (Section 4.6.5.1.d) consists of three parts: 1) flow rate and pressure drop across the filters; 2) SFAS Actuation; and 3) verifying filter cooling bypass valves can be manually opened.

The flow rate and pressure drop across the filters were conducted in January 1981 for the 18-month surveillance requirement in Section 4.6.5.1.b. Thus, the only sections to be delayed are the acteation of the system on a SFAS signal and verification that the filter cooling bypass valves can be

manually opened. As past tests results have shown, no problems with signal actuation or manual opening of the bypass valves.

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The monthly test of the EVS verifies the proper operation of the fans and acceptable pressure drop across the filters. Due to these factors, it is concluded that a delay of 10 days in the performance of this test will not result in an increase in risk to the health and safety of the public. Therefore, this is not an unreviewed safety question.

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