ML20065G142

Application for Amend to License NPF-3,revising TS 3/4.1.1.1 Re Applicable Bases for Reactivity Control Sys & Emergency Core Cooling Sys

ML20065G142
Person / Time
Site:	Davis Besse
Issue date:	03/30/1994
From:	Shelton D CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20065G145	List: ML20065G142 ML20065G147
References
2210, NUDOCS 9404120196
Download: ML20065G142 (12)

Text

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CENTERDOR ENERGY 6200 00k Tree Boulevard Mail Address- Donald C. Shelton independence OH P.O. Box 94661 Senior Vice President j 216-447 3153 Cleveland, OH 44101-4661 Nuclear i Fox 216-447-3123

. Docket Number 50-346 License' Number NPF-3 Serial Number 2210 March 30, 1994 United States Nuclear Regulatory Commission Document Control Desk Vashington, DC 20555 Subj ect s License Amendment Application to Revise Technical Specifications and Applicable Bases for Reactivity. Control Systems and Emergency Core Cooling Systems ,

Gentlemen Enclosed is an application-for an amendment to the Davis-Besse Nuclear-Power Statiori (DBNPS), Unit Number 1 Operating License Number NPF-3, Appendix A, rechnical Specifications, to reflect the changes attached.

The proposed changes involve Technical Specification (TS) 3/4.1.1.1, Reactivity Control Systems - Boration Control - Shutdown Margin; TS 3/4.1.2.8, Reactivity Control Systems - Borated Vater Sources -

Shutdown; TS 3/4.1.2.9, Reactivity Control Systems - Borated Vater Sources - Operating; associated Bases 3/4.1.2, Boration Systems; TS 3/4.5.1, Emergency Core Cooling Systems (ECCS) - Core Flooding Tanks; TS 3/4.5.2, Emergency Core Cooling Systems - ECCS Subsystems -

Tavg 2 280'F; TS 3/4.5.4, Emergency Core Cooling Systems - Borated -

Vater Storage Tank; associated Bases 3/4.5, Emergency Core Cooling Systems (ECCS); and TS 3/4.10.4, Special Test Execptions - Shutdown Margin.

The proposed changes would increase the required boration flovrate in the event the required SHUTDOWN MARGIN is not met, and increase the minimum boron concentration and/or volume requirements for the Boric Acid Addition System (BAAS), Borated Vater Storage Tank (BUST), and Core Flooding Tanks (CFT), thereby adding flexibility for future core designs, including the upcoming Cycle 10 reload. The proposed changes vould also revise the Action statements for an inoperable BVST or CFT to make them more consistent with NUREG-1430 (Revised Standard i Technical Specifications for Babcock & Vilcox Pressurized Vater '

Reactors), and would revise the Surveillance Requirements relating to trisodium phosphate (TSP) to clarify them and make them easier to perform. Various administration and editorial changes are also ]'

0800 5 $roposed. 94o41201,6 ,40330 PDR ADOCK 05000346 P PDR \ l T

Operating Companies: g  !

i Cleveland Electnc illuminating Toledo Edison (g j 4

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- Docket Numbar 50-346 Licensa Number NPF Serial Number 2210 Page-2 Toledo Edison requests that this-amendment'be issued by the NRC by October 1,.1994, the currently scheduled commencement date for the Ninth Refueling Outage. .

Should you have any questions or' require additional information, please s contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs,-at (419) 249-2366.

1 Ver truly yours, i

8 Dc5 Enclosure cc: J. D. Hartin, Regional Administrator, NRC Region III G. West, DB-1 NRC/NRR Project Manager-S. Stasek, NRC Region'III, DB-1 Senior Resident Inspector .

J. R. V1111ams, Chief of Staff, Ohio Emergency Management. Agency, 3 State of Ohio (NRC Liaison) i Utility Radiological Safety Board.

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Docket Number 50-346 Licensa Number NPF-3 Serial Number 2210 Enclosure Page 1 APPLICATION FOR AMENDHENT TO FACILITY OPERATING LICENSE NPF-3 DAVIS-BESSE NUCLEAR POVER STATION UNIT NUMBER 1 Attached are requested changes to the Davis-Besse Nuclear Power Station, Unit Number 1 Facility Operating License Number NPF-3. Also included is the Safety Assessment and Significant Hazards Consideration.

The proposed changes (submitted under cover letter Serial Number 2210) concern:

Appendix A, Technical Specification 3/4.1.1.1, Reactivity Control Systems, Boration Control, Shutdown Margin Appendix A, Technical Specification 3/4.1.2.8, Reactivity Control Systems, Borated Vater Sources - Shutdown Appendix A, Technical Specification 3/4.1.2.9, Reactivity Control Systems, Borated Vater Sources - Operating Appendix A, Technical Specification Bases 3/4.1.2, Boration Systems Appendix A, Technical Specification 3/4.5.1, Emergency Core Cooling Systems (ECCS), Core Flooding Tanks Appendix A, Technical Specification 3/4.5.2, Emergency Core Cooling Systems, ECCS Subsystems - Tavg h 280"P Appendix A, Technical Specification 3/4.5.4, Emergency Core Cooling Systems, Borated Vater Storage Tank Appendix A, Technical Specification Bases 3/4.5, Emergency Core Cooling Systems (ECCS)

Appendix A, Technical Specification 3/4.10.4, Special Test Exceptions, Shutdown Margin For: D. C. Shelton, Senior Vice President - Nuclear l

By: &M J. K. Wood, Plant Kihager l

Sworn to and subscribed before me this 30th day of March, 1994. J dll /A) < Afb')

Notary Publid, State of Ohio El'W3 L CM33 r 3TI. TEM CH;0 f,l . kb$$GUA05 l

Docket Numbar 50-346 Licensa Numbar NPF-3 Serial Numbar 2210 Enclosure Page 2 The following information is provided to support issuance of the requested changes to Davis-Besse Nuclear Power Station, Unit Number 1 Operating License Number NPF-3, Appendix A, Technical Specification (TS) 3/4.1.1.1, Reactivity Control Systems - Boration Control -

Shutdown Margin; TS 3/4.1.2.8, Reactivity Control Systems - Borated Vater Sources - Shutdown; TS 3/4.1.2.9, Reactivity Control Systems -

Borated Vater Sources - Operating; associated Bases 3/4.1.2, Boration Systems; TS 3/4.5.1, Emergency Core Cooling Systems (ECCS) - Core Flooding Tanks; TS 3/4.5.2, Emergency Core Cooling Systems - ECCS Subsystems - Tavg 2 280'F; TS 3/4.5.4, Emergency Core Cooling Systems -

Borated Water Storage Tank; associated Bases 3/4.5, Emergency Core Cooling Systems (ECCS); and TS 3/4.10.4, Special Test Exceptions -

Shutdown Margin.

A. Time Required to Implement: This change is to be implemented within 90 days after NRC issuance of the License Amendment, or during the Ninth Refueling Outage, whichever occurs later.

B. Reason for Change (License Amendment Request Number 93-0011, Revision 0):

The proposed changes vould increase the required boration flovrate in the event the required SHUTDOWN MARGIN is not met, and increase the minimum boron concentration and/or volume requirements for the Boric Acid Addition System (BAAS), Borated Vater Storage Tank (BUST), and Core Flooding Tanks (CFT), thereby adding flexibility for future core designs, including the upcoming Cycle 10 reload. The proposed changes would also revise the Action statements for an inoperable BVST or CFT to make them more consistent with NUREG-1430 (Revised Standard Technical Specifications for Babcock & Vilcox Pressurized Vater Reactors), and would revise the Surveillance Requirements relating to trisodium phosphate (TSP) to clarify them and make them easier to perform. Various administration and editorial changes are also proposed.

C. Safety Assessment and Significant Hazards Consideration: See Attachment 1

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Docket Numbar 50-346 License Numbar NPF-3 Serial Number 2210 )

Attachment j Page 1 SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 93-0011 TITLE:

Revision of Technical Specification (TS) 3/4 1.1.1, Reactivity Control Systems -

Boration Control - Shutdown Margin, TS 3/4.1.2.8, Reactivity Control Systems -

-Borated Water Sources - Shutdown, TS 3/4.1.2.9, Reactivity Control Systems -

Borated Water Sources - Operating, associated Bases 3/4.1.2, Boration Systems, TS 3/4.5.1, Emergency Core Cooling Systems (ECCS) - Core Flooding Tanks, TS 3/4.5.2, Emergency Core Cooling Systems - ECCS Subsystems - Tavg > 280'F, TS 3/4.5.4, Emergency Core Cooling Systems - Borated Vater Storage Tank, associated Bases 3/4.5, Emergency Core Cooling Systems (ECCS), and TS 3/4.10.4, Special Test Exceptions - Shutdown Margin.

DESCRIPTION:

The purpose of the proposed changes is to modify the Davis-Besse Nuclear Power Station (DBNPS) Operating License NPF-3, Appendix A Technical Specifications (TS) and associated Bases. The proposed changes would increase the required boration flovrate in the event the required SHUTDOVN MARGIN is not met, and increase the minimum boron concentration and/or volume requirements for the Boric Acid Addition System (BAAS), Borated Vater Storage Tank (BWST), and Core

! Flooding Tanks (CFT), thereby adding flexibility for future core designs, including the upcoming Cycle 10 reload. The proposed changes vould also revise the Action statements for an inoperable BVST or CFT and the Surveillance l

Requirement relating to boron concentration sampling of the CFT to make them more consistent with NUREG-1430 (Revised Standard Technical Specifications for Babcock & Wilcox Pressurized Water Reactors), and would revise the Surveillance Requirements relating to trisodium phosphate (TSP) to clarify them and make them easier to perform. Various administrative and editorial changes are also proposed. Each of these changes is described in further detail below.

TS 3/4.1.1.1, Reactivity Control Systems - Boration Control - Shutdown Margin -

- Revise the TS Action statement to increase the required boration flovrate I from 18 gpm to 25 gpm, in the event the SHUTD0VN MARGIN requirement is not met. I Consistent with this change, revise the TS 3/4.10.4 Action Statement. I TS 3/4.1.2.8, Reactivity Control Systems - Borated Vater Sources - Shutdown, and

! the associated TS Bases 3/4.1.2 -- Increase the minimum BAAS volume from j 600 gallons to 700 gallons and increase the minimum boron concentration of the BVST from 1800 ppm to 2100 ppm.

1 TS 3/4.1.2.9, Reactivity Control Systems - Borated Water Sources - Operating, )

and the associated TS Bases 3/4.1.2 -- Revise Figure 3.1-1 " BAAS Minimum l

, Required Volume as a Function of Boric Acid Concentration Required in i Modes 1-4," increase the minimum boron concentration of the BVST from 1800 ppm to 2100 ppm, and replace the present TS Action 3.1.2.9.b with new TS Actions 3.1.2.9.b and 3.1.2.9.c, to read as follows: ,

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Licensa Numbar NPF-3 Ssrial Numbar 2210 Attachment Page 2

b. Vith the BVST inoperable because of boron concentration or temperature not within limits, restore the BWST to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT STANDBY vithin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTD0VN vithin the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

c. With the BVST inoperable for reasons other than boron concentration or temperature not within limits, restore the BVST to OPERABLE status within one hour or be in at least HOT STANDBY vithin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

TS 3/4.5.1, Emergency Core Cooling Systems (ECCS) - Core Flooding Tanks, and the associated TS Bases 3/4.5.1 -- Increase the minimum boron concentration of the CFTs from 1800 ppm to 2100 ppm, and replace the present TS Actions 3.5.1.a and 3.5.1.b with new TS Actions, to read as follows:

a. With one CPT inoperable because of boron concentration not within limits, restore the inoperable CFT to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANDBY vithin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the RCS pressure to less than 800 psig within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

b. With any CFT inoperable for reasons other than boron concentration not within limits, restore the CFT to OPERABLE status within one hour or be in HOT STANDBY vithin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the RCS pressure to less than 800 psig within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

In addition, revise Surveillance Requirement (SR) 4.5.1.b to read as follows:

b. At least once per 31 days, and within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of each solution volume increase of 280 gallons that is not the result of addition from the borated water storage tank (BVST), by verifying the boron concentration of the CFT solution.

TS 3/4.5.2 Emergency Core Cooling Systems - ECCS Subsystems - Tavg 2 280'F, and the associated TS Bases 3/4.5.2 -- Revise Surveillance Requirement (SR) 4.5.2.d.4 to remove the words " solid granular," and revise SR 4.5.2.d.6 to read as follows:

6. Verifying that when a representative sample of TSP from a TSP storage  ;

basket is submerged, without agitation, in at least one liter of 180 +

10'F borated water from the BVST, such that the resulting concentration of TSP is less than 0.84 grams per liter, the pH of the mixed solution is raised to 2 7 (measured at 77'F) within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

TS 3/4.5.4, Borated Vater Storage Tank, and the associated TS Bases 3/4.5.4 --

Increase the minimum boron concentration of the BVST from 1800 ppm to 2100 ppm, and replace the present TS Action 3.5.4 with new TS Actions 3.5.4.a and 3.5.4.b, to read as follows:

a. Vith the BVST inoperable because of boron concentration or temperature '

not within limits, restore the BUST to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> l or be in at least HOT STANDBY vithin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

b. Vith the BVST inoperable for reasons other than boron concentration or

Docket Numbar 50-346 i 1

License Number NPF-3 Serial Number 2210 Attachment Page 3 temperature not within limits, restore the BVST to OPERABLE status within one hour or be in at least HOT STANDBY vithin the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. l Additional administrative and editorial changes are also proposed, as shown in the attached, marked-up changes to the Operating License.

SYSTEMS, COMP 0NENTS, AND ACTIVITIES AFFECTED:

The systems and components affected are the BAAS, the BVST, and the CFTs.

Surveillance testing activities involving TSP chemistry are also affected.

SAFETY FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS AND ACTIVITIES:

Boric Acid Addition System (BAAS)

The BAAS provides sufficient concentrated boric acid solution to increase the Reactor Coolant System (RCS) baron concentration from Hot Full Power (HFP) boron concentration to the Cold Shutdown (CSD) boron concentration at any time during the operating cycle. The BVST provides alternate boration capability.

The HFP boron concentration is the concentration which maintains the reactor critical at 100% Rated Thermal Power (RTP) with an RCS average temperature of 582'F, and at equilibrium xenon conditions. The CSD boron concentration is the concentration required to maintain the reactor with a 1%6k/k Shutdown Margin (SDM), xenon free, at 70'F, with the most reactive control rod stuck out.

Borated Vater Storage Tank (BVST)

The BVST provides an alternate boration capability to the BAAS. The safety function of the BVST is to provide a sufficient supply of borated water to the Emergency Core Cooling Systems (ECCS) in order ensure adequate inventory for recirculation and to maintain the reactor with a 1%6k/k SDM in the event of a Loss of Coolant Accident (LOCA).

Core Flooding Tanks (CFTs)

The CFTs provide the immediate reflood of the reactor following a design basis Large Break LOCA (LBLOCA) so as to ensure that the fuel cladding peak temperature vill remain below the 10 CFR 50.46 criteria of 2200'F following a LBLOCA prior to the refill of the reactor by the ECCS HPI/LPI systems.

Trisodium Phosphate (TSP) Chemistry Surveillance Testqng The safety function of the TSP contained in baskets in the containment normal sump is to neutralize the acidity of the post-LOCA borated water mixture prior to establishing containment emergency sump recirculation. The BVST borated water has a nominal pH value of approximately 5. Raising the borated water mixture to a pH value of 7 vill ensure that chloride stress corrosion does not l

Docket Number 50-346

~ License Number NPF-3 i Serial Number 2210 i Attachment i l

Page 4 occur in austenitic stainless steels in the event that chloride levels increase l as a result of contamination on the surfaces of the reactor containment l building. Also, a pH of 7 is assumed for the containment emergency sump for l iodine retention and removal post-LOCA by the containment spray system. The l

surveillance testing assures that the TSP is adequate to perform the required pH adjustment.

EFFECTS ON SAFETY:

The proposed change to TS 3/4.1.1.1 to revise the TS Action statement to increase the required boration flovrate from 18 gpm to 25 gpm, in the event the SHUTD0VN HARGIN requirement is not met, vill ensure that the boration rate is adequate for restoring the required SHUTD0VN MARGIN for anticipated future core designs. The proposed change to TS 3/4.10.4 to revise the TS Action Statement to increase the required boration flovrate from 18 gpm to 25 gpm makes this l

Action statement consistent with TS 3/4.1.1.1. These proposed changes are in the conservative direction and would have no adverse effect on plant safety.

The proposed changes to TS 3/4.1.2.8 to increase the minimum required BAAS volume and to increase the minimum required BVST boron concentration vill ensure l that adequate boration capability is maintained for anticipated future core l designs. These proposed changes are in the conservative direction and would l

have no adverse effect on plant safety.

The proposed changes to TS 3/4.1.2.9 and TS 3/4.5.4 to revise TS Figure 3.1-1 and to increase the minimum required BVST boron concentration vill ensure that adequate boration capability is maintained for anticipated future core designs.

These proposed changes are in the conservative direction and would have no adverse effect on plant safety.

The proposed changes to the TS 3/4.1.2.9 and TS 3/4.5.4 Action statements increase the allovable outage time for restoring the BVST to operable status, in the event the BWST is inoperable because of boron concentration or temperature not within limits. This change vill allow a reasonable time period to restore the boron concentration or temperature to within limits, and is consistent with NUREG-1430, " Revised Standard Technical Specifications for Babcock & Wilcox Pressurized Vater Reactors." The contents of the BWST will remain available for injection during the eight hour time period allowed for restoring the boron concentration or temperature to within limits. Therefore, there vould be no adverse effect on plant safety.

The proposed changes to TS Bases 3/4.1.2 and 3/4.5.4 are associated with the above proposed changes to T3 3/4.1.2.8, 3/4.1.2.9, and 3/4.5.4 and would have no adverse effect on plant safety.

The proposed change to TS 3/4.5.1 to increase the minimum required CFT boron concentration vould ensure that the minimum boron concentration of the CFTs is the same as the minimum proposed boron concentration for the BVST, as assumed in l the reload analysis for the post-LOCA borated water mixture concentration. This  !

proposed change is in the conservative direction and would have no adverse effect on plant safety.  ;

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License Number NPF-3 Serial Number 2210 Attachment Page 5 The proposed change to the TS 3/4.5.1 Action statement increases the allowable outage time for restoring the CFT to operable status, in the event the CFT is l inoperable because of boron concentration not within limits. This change vill

' allow a reasonable time period to restore the boron concentration to within limits, and is consistent with NUREG-1430. The contents of the CFT will remain available for injection during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period allowed for restoring the boron concentration to within limits. The effects of reduced boron concentration on core suberiticality during reflood (post-LOCA) are minor because the initial voiding maintains the reactor suberitical. Also, the boiling of the ECCS vater in the core during reflood concentrates the boron in l

the saturated liquid that remains in the core. In addition, the boron l requirements are based on the average boron concentration of the total volume of l both CFTs, therefore the effect of only one CFT being outside boron concentration limits is lessened. For these reasons, there vould be no adverse effect on plant safety.

The proposed change to the TS 3/4.5.1 Action statement also changes the required ending plant condition, in the event CFT operability cannot be restored, from

" HOT SHUTDOWN" to " HOT STANDBY vith RCS pressure less than 800 psig".

j TS 3/4.5.1 is applicable in Modes 1 and 2 and in Mode 3 with reactor coolant pressure >800 psig. In Mode 3 with RCS pressure belov 800 psig, the CFT motor operated isolation valves are closed to isolate the CFTs from the RCS. This allows RCS cooldown and depressurization without discharging the CFTs into the RCS or requiring depressurization of the CFTs. The above change vould make the Action statement consistent with the TS 3/4.5.1 Applicability and would have no adverse effect on plant safety.

The proposed change to the TS 3/4.5.1 Action statement also would eliminate the separate Action statement (current TS Action 3.5.1.b) for a CFT inoperable due to the isolation valve being closed. Instead this condition vould be covered under the proposed TS Action 3.5.1.b, which allows one hour to restore the CFT to operable status. The current TS Action 3.5.1.b states that with the CFT inoperable due to the isolation valve being closed, either immediately open the isolation valve, or proceed with a plant shutdown within one hour. As noted above, the proposed Action statement is consistent with NUREG-1430. Also, the one-hour time period allowed for restoring operability vill still ensure that prompt action vill be taken, minimizing the time the plant is potentially exposed to a LOCA in this condition. Therefore, there would be no adverse effect on plant safety.

The proposed change to the TS 3/4.5.1 Surveillance Requirement (SR) 4.5.1.b would eliminate the requirement to sample the CFT boron concentration within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of a solution volume increase of >80 gallons, if the solution volume increase was the result of addition from the BVST. This change is consistent with NUREG-1430. Since the water contained in the BVST is within the CFT boron concentration requirements, addition of water to the CFT from the BUST vould not result in the CFT boron concentration being out of limits, and there is no need to perform a sample within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Therefore, this change vould have no adverse effect on plant safety.

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The proposed changes to TS Bases 3/4.5.1 are associated with the above proposed changes to TS 3/4.5.1, and would have no adverse effect on plant safety.

The proposed change to the TS 3/4.5.2 Surveillance Requirement (SR) 4.5.2.d.4 would remove the words " solid granular" from the description of TSP. TSP was originally added to the baskets in solid granular form, however the TSP granules clump together over the years. The present TS wording ir overly descriptive and ,

could cause interpretive confusion over whether the TSP presently in the racks l is " granular." The purpose of this SR is to verify a minimum volume and density l of TSP, and the degree to which the TSP can be described as " granular" is l irrelevant. The proposed change is a clarification and would have no adverse l effect on plant safety. l l The proposed change to the TS 3/4.5.2 SR 4.5.2.d.6 vould allow the TSP and j

' borated water sample sizes for pH determination to be proportionately decreased. )

The proposed changes would not affect the intent of the SR but would make it  ;

easier for the technician to perform the SR, would minimize radvaste, and would l reduce the consequences of a potential radioactive spill. Therefore, this I l

proposed change vould have a positive impact on plant safety.

The proposed change to the TS 3/4.5.2 SR 4.5.2.d.6 would also increase the required pH value from a pH of 6 to a pH of 7, and would specify a temperature l (77'F) at which the pH should be measured. The DBNPS Updated Safety Analysis l

Report (USAR) Sections 6.2.2.2.2, 6.3.3.2, 9.3.3.2, and 15.4.6.4 state that the  ;

i post-LOCA sump mixture should be at a pH of 7 or greater prior to the '

I recirculation phase to prevent chloride stress corrosion and ensure iodine retention. This change is conservative and would make the TS SR consistent with the USAR, and therefore would have no adverse effect on plant safety. A pH measurement temperature of 77'F (25"C) is normal practice. NUREG-0800 Standard i Review Plan 6.1.1, " Engineered Safety Features Materials," specifies that all pH I values are at 25"C. This change is a clarification and vould have no adverse effect on plant safety.

The proposed changes to TS Bases 3/4.5.2 and 3/4.5.3 are associated with the above proposed changes to TS 3/4.5.2, and would have no adverse effect on plant ,

safety. l l The additional administrative and editorial changes proposed, as shown in the I attached, marked-up changes to the Operating License, would have no adverse effect on plant safety.

SIGNIFICANT HAZARDS CONSIDERATION: 1 The Nuclear Regulatory Commission has provided standards in 10CFR50.92(c) for i determining whether a significant hazard exists due to a proposed amendment to an Operating License for a facility. A proposed amendment involves no significant hazards if operation of the proposed facility in accordance with the proposed changes vould: (1) Not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) Not create the possibility of a new or different kind of accident from any accident 1

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Docket Number 50-346 License Number NPF-3 Serial Number 2210 Attachment Page 7 previously evaluated; or (3) Not involve a significant reduction in a margin of safety. Toledo Edison has reviewed the proposed change and determined that a significant hazards consideration does not exist because operation of the Davis-Besse Nuclear Power Station (DBNPS), Unit No. 1, in accordance with these changes vould:

la. Not involve a significant increase in the probability of an accident previously evaluated because no accident initiators, conditions or assumptions are significantly affected by the proposed changes.

The proposed changes vould increase the required boration flovrate in the event the required SHUTD0VN MARGIN is not met, increase the minimum required volume for the Boric Acid Addition System (BAAS) and increase the minimum required boron concentration for the Borated Vater Storage Tank (BVST) and the Core Flooding Tanks (CFT). The proposed changes would also revise the Technical Specification (TS)

Action Statements for the BVST and the CFT, revise the TS Surveillance Requirement relating to boron concentration sampling of the CFT, and would revise the TS Surveillance Requirements involving trisodium phosphate chemistry. In addition, various administrative and editorial changes, including changes to the TS Bases, are proposed.

As stated above, none of these proposed changes involve accident initiators, conditions, or assumptions.

Ib. Not involve a significant increase in the consequences of an accident previously evaluated because no accident conditions or assumptions are affected by the proposed changes.

The proposed changes for the minimum required boron concentrations and volumes for the BAAS, BVST, and CFT comply with existing requirements to maintain a 1%6k/k shutdown margin (SDM) at all times, and are consistent with reload and LOCA analysis. Therefore, the accident condition assumption of 1%6k/k SDM at the initiation of an accident vill still be met and the radiological consequences vill be as previously evaluated.

The proposed changes do not alter the source term, containment isolation, or allovable releases. The proposed' changes, therefore, vill not increase the radiological consequences of a previously evaluated accident.

2a. Not create the possibility of a new kind of accident from any accident previously evaluated because no new accident initiators or assumptions are introduced by the proposed changes. As stated in la, the proposed changes do not affect any accident initiators and are not initiatcrs themselves. The proposed changes do not alter any accident scenarios.

Docket Numbar 50-346 License Number NPF-3 Serial Number 2210 Attachment Page 8 l

2b. Not create the possibility of a different kind of accident from any J accident previously evaluated because the proposed changes only affect  ;

existing components, systems, and functions and do not introduce any l new requirements that cannot be met with the existing components, i systems, and functions. The proposed changes do not alter any accident scenarios.

3. Not involve a significant reduction in a margin of safety. The proposed changes to the minimum required boron concentration and volumes for the BAAS, BUST, and CFT would ensure the margin of safety for reactor subcriticality is maintained at all times for anticipated future core designs.

The proposed change to the TS Action statement to increase the required boration flovrate in the event the SHUTD0VN MARGIN requirement is not met, vould ensure that the boration rate is adequate for restoring the required SHUTDOWN MARGIN for anticipated future core designs.

The proposed changes to the TS Action statements for the BVST and the CFT ensure that the plant is maneuvered in a timely and conservative manner, without challenging any plant systems, while minimizing the time the plant vould be exposed to a LOCA vith assumptions not being met.

The proposed changes to the TS Surveillance Requirements associated with trisodium phosphate chemistry would clarify the requirements, make it easier to perform testing, minimize radvaste generation, and reduce the consequences of a potential radioactive spill. The proposed changes vould also make the requirements consistent with the DBNPS Updated Safety Analysis Report.

The proposed change to the TS Surveillance Requirement associated with boron concentration sampling of the CFT would eliminate an unnecessary requirement and make the Surveillance Requirement consistent with NUREG-1430.

None of these changes vould adversely affect the margin of safety.

CONCLUSION:

On the basis of the above, Toledo Edison has determined that the License Amendment Request does not involve a significant hazards consideration. As this License Amendment Request concerns a proposed change to the Technical Specifications that must be reviewed by the Nuclear Regulatory Commission, this License Amendment Request does not constitute an unreviewed safety question. l l

ATTACHMENT:

l Attached are the proposed marked-up changes to the Operating License.

l s