ML20101M195
| ML20101M195 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/20/1984 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20101M193 | List: |
| References | |
| NUDOCS 8501020520 | |
| Download: ML20101M195 (6) | |
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NUCLEAR REGULATORY COMMISSION o
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULITION SUPPORTING AMENDMENT NO. 82 TO FACILITY OPERATING LICENSE NO. NPF-3 E
TOLEDO EDISON COMPANY
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AND THE CLEVELAND ELECTRIC ILLUMINATING COMPANY f
DAVIS-BESSE NUCLEAR POWER STATI0F, UNIT NO. 1
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DOCKET NO. 50-346 4
1.0 INTRODUCTION
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By letter dated December 3, 1984, Toledo Edison Company submitted an application to amend Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1.
The proposed amendment would change
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Section 1.6 of the Appendix A Technical Specifications. This section r
provides the definition of OPERABLE.
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The modification to the definitico would be effective from the time of issuance of the amendment to until the facility leaves operational Mode 2 and enters operational Mode 1 for Cycle 5.
The modification would remove from consideration the status of the startup feedwater system when determining the OPERABILITY of the auxiliary feedwater system. The modification would permit the use of the startup feedwater system in the plant startup sequence from the refueling outage for Cycle 5 and provides for its continued use to i
conduct zero power physics testing for the newly refueled core.
Toledo Edison Company has asked for expedited action on this amendment request and has provided justification for the consideration of exigent l
circumstances by the Comission, il 2.0 DISCUSSION l
On May 15, 1984, operating personnel at the Davis-Besse Nuclear Power Station g
identified one high and three moderate energy lines in auxiliary feedwater s
(AFW) pump rooms 237 and 238 whose failures have not been analyzed in
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accordance with the criteria given in Section 3.6 of the Final Safety Analysis Report (FSAR).
1he lines are the startup feedwater pump (SUFP)
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discharge line (high energy), SUFP suction line and turbine plant cooling water (TPCW) lines which supply coolant to the SUFP. The SUFP 1s, located in j
AFW pump room 238. Unless the startup feedwater system and TPCW are isolated from outside the AFW pump rooms, a SUFP discharge line break within the room l
can jeopardize AFW pump 1-2 due to jet impingement or pipe whip; breaks in any of the other lines can jeopardize AFW pump 1-2 or AFW pump 1-1, located in room 237, by flooding or high temperature. Upon discovery of the situation, Toledo Edison Company closed valves located outside the AFW pump rooms to t
I isolate the SUFP and TPCW piping.
8501020520 841220 PDR ADOCK 05000346 P
g Technical Specification 3.7.1.2 requires two independent AFW pumps and I
associatedflowpathstobeOPERABLEwheneverthestationisopergtingin Modes 1, 2 or 3.
With the present arrangement of the SUFP system, the AFW system is considered not to meet the operability requirement unless the SUFP F
system is isolated, s
The Davis-Besse station has been shutdown for refueling since September 11, f
1984, and is presently in the startup sequence for Cycle 5.
The station is b
expected to be ready for transition into Mode 3 about December 23, 1984, and for transition into Mode 2 about December 26, 1984. When the reactor is brought to criticality in Mode 2, zero power physics testing of the newly refueled core will commence. As long as 7 to 14 days may be required for this testing. Toledo Edison Company has proposed the temporary modification to the definition of OPERABILITY to permit use of the SUFP in Modes 2 and 3 I
to avoid a delay in plant startup.
(In another licensing action related to l
this issue, the Comission is considering the issuance of an amendment that F
would permit the use of the SUFP when needed for the entire Cycle 5.
This f
l other proposed action has been the subject of a notice in the Federal Register and will not be issued prior to December 29,1984.)
3.0 EVALUATION 4
Toledo Edison Company has determined that it is necessary to use the SUFP to conduct the zero power physics testing because of the need to control l
adequately the appropriate test conditions.
It is not practical to use the main feedwater pump for such control because steam necessary to drive the main feedwater pump turbines would have to be supplied from the auxiliary boiler. This boiler is not reliable for this purpose. The poor reliability of the boiler to drive the main feedwater pump turbines could result in increased challenges to reactor safety systems and extend significantly the time required to accomplish zero power physics testing. Toledo Edison Company has evaluated the probability of a SUFP or TPCW piping failure and has detemined that loss of the AFW pumps from such an event is not a significant contributor to total AFW system unavailability. However, as a compensatory measure, the licensee will locate an operator in the AFW/SUFP area whenever the SUFP lines are not isolated, are pressurized, and the facility is in operational Modes 2 or 3.
Upon any indication of a pipe leak or failure in the SUFP piping, the
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operator will trip the SUFP locally or contact the control room to trip the SUFP. The operator will then close the SUFP and/or TPCW isolation valves I
which are outside the i P/AFW area.
In the unlikely event the SUFP or TPCW piping should fail and cause both trains o' AFW to become inoperable, adequate cooling can be provided using feed and bleed until action can be taken to restore AFW or main feedwater.
The Davis-Besse reactor will have been shutdown for more than 100 days before the zero power physics tests are perfomed. Therefore, the decay-heat level e
will be very low - less than 0.1% of full power.
In an event in which.all t
feedwater capability is lost, the Davis-Besse emergency procedures require r
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the operator to respond by 1) opening the pilot operated relief valve (PORV),
- 2) opening the reactor coolant system high point vents, 3) opening the pressurizer vent, and 4) starting the two makeup pumps. The procedure also requires the operator to ensure that the two high pressure injection pumps start when the coolant system pressure drops to 1650 psig.
The licensee has determined that adequate cooling could be provided by one L
high pressure injection or one makeup pump and either the PORY or one reactor system high point vent. Cooling in this mode would provide time to activate I
i other means of feedwater addition.
For example, a main feedwater pump, if available, could be activated.
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The staff concludes that complete loss of feedwater resulting from operation t
i of the SUFP during the 7 to 14 days of zero power physics testing is very unlikely and that the SUFP may be utilized for this purpose without
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endangering the public health and safety. However, in the unlikely event a complete loss of feedwater does occur, the very low level of decay heat can e
be removed using feed and bleed. Therefore, the requested Technical l
Specification change is acceptable.
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4.0 EXIGENT CIRCUMSTANCES
The procedures to be followed on applications received after May 6, 1983, requesting an amendment to an operating license are stated in 10 CFR 50.91.
j These procedures require, among other actions, that the Commission will publish, in the Federal Regist_e_r, a notice which 1) contains the staff's proposed determination with respect to significant hazards considerations of the proposed amendment, 2) provides a description of the amendment and I
facility involved, and 3) solicits public comments and offers a 30-day coment period and opportunity to request a hearing. Nomally, an amendment will not i
be issued until this comment period expires.
These procedures allow for issuing an amendment before the expiration of the
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30-day coment period if exigent circunstances exist. Where such circumstances exist and time does not permit the Comission to publish the 30-day notice in the Federal Register, the Commission may use local media to inform the public of the amendment requesi and of the Comission's proposed determination with respect to significant hazards considerations and to provide a reasonable opportunity for public coment.
If the Comission determines that the amendment involves no significant hazards considerations, I.:
it may thereafter issue the amendment without further wait. The Comission i
will publish a notice in the Federal Register providing opportunity for hearing and public coment after the amendment is issued. A Public Notice in accordance with NRC regulations appeared with respect to this amendment on December 8, 1984, in the Toledo Blade, on December 13, 1984, in the Fremont (OH) News Messenger, and on December 12, 1984, in the Port Clinton (OH) News HeraTH-With respect to this amendment, the Toledo Edison Company has explained the I
circumstances leading to this exigency. We have reviewed this explanation and find that an exigency does, indeed, exist.
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k The following describes the exigent circumstances:
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a)
On May 18, 1984, Toledo Edison Company discovered the circumstances regarding the SUFP system and established operational restrictions and other procedures regarding use of the SUFP system. These actions were S
taken to avoid interfering with continued operation of the unit and to operate the facility consistent with descriptions contained in the Final l'
Safety Analysis Report. The licensee instituted actions to identify plant modifications to resolve the prablem but later concluded that there was insufficient time to tnplement viable modifications during the Fall 1984 w
refueling outage.
b)
On October 18, 1984, Toledo Edison Company submitted to the Comission a request for approval to use the SUFP for nomal plant startup and L.
shutdown. Toledo Edison Company submitted supporting technical analysis to demonstrate that operation of the SUFP presented no significant
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increased risk due i.o its operation. Upon review, the Comission detemined that the Toledo Edison Company request involved an unreviewed l
safety question and would require, pursuant to 10 CFR 50.59(c), an y
amendment to the operating license.
4 c)
Thereupon, on November 12, 1984, Toledo Edison Company submitted a request for license amendment to add a license condition requiring certain compensatory actions whenever the SUFP is in use during Modes 1, 2 or 3, reouiring isolation of the system when not in use, and requiring a modification to the SUFP system before the end of the next refueling cycle to pemanently remove the hazard to auxiliary feedwater pumps from SUFP operation. The staff, upon review of the application, found that because that application reouested approval for the entire Cycle 5, a determination that the amendment involved no significant hazards considerations could not be made. The applicable Federal Register notice was published November 28, 1984, and the amendment will not be issued prior to Decenber 29, 1984.
i d)
On December 3, 1984, Toledo Edison Company submitted application for this amendment with a request for prompt action because the SUFP would be needed on a one-time basis to perfom the zero power physics tests in Mode 2 during plant startup. The current startup schedule will require that this amendment be issued no later than December 23, 1984, to avoid delaying restart of the unit. While the plant could be started up and operated at low power without this change, initial startup from a refueling outage without this change is undecirable because it could extend or prevent performance of required zero-power core physics testing and could result in unnecessary challenges to the plant safety systems.
In connection with requests for consideration of exigent circumstinces,.the 1
Comission expects licensees to submit timely applications. We conclu~de that reasonable diligence was applied by the licensee, but that the exigency results from late recognition by the licensee of the need for SUFP operation e
to perform the zero power physics tests.
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5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
DETERMINATION
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The Commission's regulations in 10 CFR 50.92 state that the Comission may make a final determination that a license amendment involves no significant hazards considerations if operation of the facility in accordance with the amendment would not:
(1)
Involve a significant increase in the probability or consequences of an accident previously evaluated; or
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(2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or y
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(3) Involve a significant reduction in a margin of safety.
j The application of these criteria to this license amendment for our final determination that no significant hazards consideration is involved is as e
follows:
g 1.
No Significant Increase in the Probability or Consequences of an Accident Previously Analyzed
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The estimated probability of a rupture of the SUFP or TPCW piping which could result in the failure of the entire AFW system has been compared to the estimated probability of AFW system failure from all other causes. This comparison shows that the expected increase in AFW system failure is not significant. The consequences of AFW system failure would be less because of th /ery low level of decay heat after more than 100 days i
of shutdown and part111 core replacement with fresh fuel.
2.
No Creation of a New or Different Kind of Accident Than Previously Analyzed
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The licensee has comitted to stationing an operator in the SUFP/AFW pump area to monitor the SUFP system for any leaks or piping failure.
Prompt action to isolate the SUFP system will preclude the occurrence of conditions which could cause both AFW trains to fail because of the f
event. Therefore, no new or different kind of accident isill be created.
3.
No Significant Reduction in a Safety Margin I
The SUFP suction and discharge lines and TPCW lines are not designed to seismic class 1 requirements. This amendment does reduce the safety margin that would otherwise be provided against seismic events.
4 However, this margin reduction is compensated for by the measures 3
described in the previous paragraph and is not considered significant.
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Accordingly, we conclude that this amendment to Facility Operating License i
Mode 1 for the upcoming Cycle 5, involves no significant hazards c,onsideration.
k NPF-3 to support startup operations of Davis-Besse Unit 1, up to but not in J
6.0 STATE CONSULTATION
In accordance with the Commission's regulations, consultation was held with the State of Ohio by telephone. The State expressed no concern either from the standpoint of safety or of our no significant hazards determination.
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7.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change in the installation or use of a facility
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component located within the restricted area as defined in 10 CFR Part 20.
7 We have determined that the amendment involves no significant increase in the 4
amounts, and no significant change in the types, of any effluents that may be
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released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards l
consideration and there has been no public coment on such finding.
tf Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no
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environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
8.0 CONCLUSION
We have concluded, based on the considerations discussed above, that:
l (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with t'le Comistirn's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Dated: December 20, 1984 Principal Contributors: Walton Jensen, and Albert De Agazio.
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