ML20090K765

Forwards Application for Amend to License NPF-3,changing TS 3.4.11, Reactor Coolant Sys - Reactor Coolant Sys Vents & TS 6.9.2, Reporting Requirements - Special Repts

ML20090K765
Person / Time
Site:	Davis Besse
Issue date:	03/13/1992
From:	Shelton D CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20090K767	List: ML20090K765 ML20090K772 ML20090K775
References
NUDOCS 9203190289
Download: ML20090K765 (4)

Text

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s 4_ DeneW C. Shehon 300 f tadmon Avenue Vce Prnident.Nxlear Toledo. OH 436520001 Dadslieue (419)249 ?300 4

Docket Number 50-346 License Number NPF-3 Setini Humber 2026 March 13, 1992 United States Nuclear Regulatory Commission Document control Desk Vashington, D. C. 20555 SubjectU License Amendment Application to Revine Technical Specification Regarding Reactor Coolant System Venting Requirements Centlement l

' Enclosed is an application for an amendment to the Davis-Besse Nuclear Power Station-(DBNPS), Unit 1 Operating License Number NPP-3. Appendix A, Technical Specifications (TS) to reflect the changes attached. The proposed changes hivolve TS 3.4.11, Reactor Coolant System - Reactor Coolant System Vents,-and TS 6.9.2, Reporting-Requiren. ants - Special Reports.

, Technical Specification 3.4.11 entrently requires that three reactor coolant system vent paths shall be operables a.) - Reactor Coolant =

System Loop 1 with vent path-through valves RC 4608A and RC 4608B b.)

Reactor Coolant System Loop 2 vith vent path through valves RC 4610A ani? RC 4610B;-and c.) Pressurizer with vent path through either valves kC 11 and RC 2A (PORV), or valves RC 239A and RC 200._ Technical Specification Action 3.4.11.a currently states."Vith.one of the above vent paths _ inoperable, restore the inoperable vent path to OPERABl.E status vithin 30 days, or, be=in HOT STANDBY vithin six hours and in-Il0T SilVTDOWN vithin the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />."

TheiroposedchangetoTS3.4.11vouldrevisetheLctionstatementto A allow continued operation in the event that either the RCS Loop 1 vent path or the RCS Loop.2 vent path (but not both) is inoperable and cannot'be restored to operable status within 30 days. Under this scenario, in lieu of_a plant shutdown, a Special Report vould be prepared and submitted to the NRC pursuant to Specification 6.9.2 within the_next 30 days outlining the action taken, the cause of i

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inopetability, and the plans and schedule for restoring the vent path to OPTRABLE status. A plant shutdown vould continue to be requited in the event the pressurizet vent path is inoperable for lenget than 30 '

days. Current Actions b, c, and d would be unchanged with the exception that they would be redesignated as Actions e, d, and e, i respectively.

Technical Specification 6.9.2 summarizes the Special Reports required to be ruhmitted to the NRC. The above described preposed change to TS  ;

3.4.11 vould add a new Special Report requirement, which vould require a new item entry to TS 6.9.2. This is an administrativo change.

A similarly worded license amendment was approved by the NRC and issued on May 8, 1989 for the Florida Pover Corporation Crystal River Unit 3 Nu lear Generating plant (Docket No. 50-302, Amendment No. 112 to License No. OPR-72). <

A recent containment entry identified the RCS Loop 2 vent path through  !

valves RC 4610A and RC 4610B as a potential source of increased RCS l leakage. To minimite RCS leakage, this flow path vas isolated by unlocking and closing upstream manual valvo RC 44. The vent path was declared inoperable and the associated TS LCO 3.4.11.a Action statement

• vas entered. As noted above, the current vording of this Action statement-allows 30 days to restore the vent path to operable status.

Folleving expiration of the 30 day allowed outage time at 1118 hours0.0129 days <br />0.311 hours <br />0.00185 weeks <br />4.25399e-4 months <br /> on March 31. 1992, a plant shutdown vill be required to commence. .

Toledo Edison estimates that the repair work on these two valves vould require a duration of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> working around-the-clock. Ilovever, due to the need to be in Cold Shutdown (Mode 5) to perform the work _and the associated Mode change testing requirements, Toledo Edison estimates that a forced outage would have a total outage duration (breaker to breaker) of approximately 14.8 days.

The RCS loop vent path valves RC 4608A, 4608D, 4610A, and 4610B are  ;

solenold-operated globe valves manufactured _by Valcor Engineering Corporation. These valves are classified as American Society of Mechanical Engineers (ASHE) Boiler and Pressure Vessel Code Section XI (1986) " Category B" valves - valves for which seat leakage in the closed position is inconsequential.for fulfillment of their function, i The valves are stroke tested, however, a valve leak rate test is not requited since these' valves are classified as Category B. . These valves -

have leaked in the past, however, the leakage could be corrected by cycling the valves, or_by allowing'the valves-to seat themselves over time._ A slight leakage from the RCS. Loop 2 vent path discharge (one drip every several minutes) was observed on November 6, 1991, and a Vork Request was initiated.- Ilovever, since the leak rate was

'. insignificant, the Vork Request was closed, and no significant leakage vas attributed'to these valves during plant _startup.

Toledo Edison plans to' attempt to reseat the-leak.ing valves (RC 4610A l

and-RC 4610B). A procedure _is' currently being developed to stroke the valves and to assess leakage. Tht procedure vill be performed prior

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Docket Number 50-346 License Number NpF-3 Serial Number 2026 Page 3 to expliation of the 30 day allowed outage time. If the leakage can be '

cortected, the RCS Loop vent path vill be testored to operable status, and Toledo Edison vill not require this change to be processed as an exigent or emergency Technical Specification change. ,

t If the NRC approves this request. Toledo Edison vill remain within the Action statement ur.;il the valves are returned to an operable status.

Thio entry vill be tracked to ensule operators are acutely aware of the inoperability of one of the vent paths. The Technical Specifications vill continue to requite that the plant be in llot Standby (Mode 3) within the next six hours, if a second vent path becomes inoperable and cannot be rectored within seventy-two hours. These compensatory measutes vill remain in effect until the plant enters a mode of operation where the Technical Specification no longer applies or until the valves are restored to an operable status. >

As discussed in clored Safety Assessment and Significant Harards consideration, 1 Edison has evaluated the appropriateness of a plant shutdown d a single inoperable RCS loop vent path and concluded that such a forced shutdown is unvarranted.  ;

In order to avoid this unvarranted plant shutdown and pending the tesults of valve stroking and leakage assessment, Toledo Edison requests-that this license amendment application be processed in the manner allowed by 10CFR$0.91(a) for exigent circumstances. Should there not be enough time for the NRC to process this amendment application as an exigent request, then Toledo Edison requests that the NRC process it as an emergency license amendment.

Toledo Edison has performed the attached environmental ansessment and determined-that the proposed amendment, if approved by the NRC, vill have no significant impact on the environment.

The State of Ohio is being transmitted a copy of this License Amendment Application by express mail to ensure an opportunity for State reviev <

and comment.

In summary, Toledo Edison requests that this amendment be issued by the NRC by March 30, 1992, in order to avoid a potential torced plant shutdown on March 31, 1992. Should Toledo Edison efforts be successful to correct the leakage so that the manual valve in the RCS loop vent path can be-reopened prior to the expiration of the 30 day allowed

-outage time, Toledo Edison vill notify the NRC not to continue processing this request on an exigent or emergency basis, j f

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Docket Number 50-346-License Number NPF-3 Serial Number 2026

. Page 4 Should further information be required, please contact Mr. Robert V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2356.

Very irp1> yours, fM ./w f erQ)

HKL/dlm cc A. B. Davis, Regional Administrator, NRC Region III J. B. Hopkins, NRC Senior Project Manager V. Levis, DB-1 NRC Senior Resident Inspector J. R. Villiams, Chief of Staff, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

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