ML20116K260

Application for Amend to License NPF-3,changing Tech Specs 1.0, Definitions, Bases 3/4.0, Applicability & 3/4.6.2.1, Containment Sys - Depressurization & Cooling Sys - Containment Spray Sys

ML20116K260
Person / Time
Site:	Davis Besse
Issue date:	08/07/1996
From:	Jeffery Wood CENTERIOR ENERGY
To:
Shared Package
ML20116K259	List: ML20116K250 ML20116K260 ML20116K263
References
2342, NUDOCS 9608140293
Download: ML20116K260 (8)

Text

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' Docket Number 50-346 License Number NPF-3 Serial Number 2342 Enclosure Page 1 APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NUMBER NPF-3 DAVIS-BESSE NUCLEAR POWER STATION UNIT NUMBER 1 Attached are the requested changes to the Davis-Besse Nuclear Power Station, Unit Numoer 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 2342) concern:

Appendix A, Technical Specifications (TS):

1.0 Definitions Bases 3/4.0 Applicability 3/4.6.2.1 Containment Systems - Depressurization and Cooling Systems - Containment Spray System 3/4.6.3.1 Containment Systems - Containment Isolation valves By:

J.K.[ood,VicePr'dsident-Nuclear Sworn to and subscribed before me this 7th day of August, 1996.

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Nothry Pub c, State of Ohio 1 J. STRAUSS Notary Pubtre, State of Ohio My Commission Empires 3/22/98 9608140293 960007 PDR ADOCK 05000346 P PDR

i a Docket Number 50-346

. License Number NPF-3 Serial Number 2342 Enclosure Page 2 The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station (DENPS), Unit Number 1 Operating License Number NPF-3, Appendix A, Technical Specification (TS) 1.0, Definitions; TS Bases 3/4.0, Applicability; TS 3/4.6.2.1, Containment Systems -

Depressurization and Cooling Systems - Containment Spray System; and TS 3/4.6.3.1, Containment Systems - Containment Isolation Valves.

A. Time Required to Implement: This change is to be implemented consistent with related changes to be proposed by separate license amendment applications, prior to the commencement of the Eleventh Refueling Outage (11RFO). The 11RF0 is presently scheduled to commence in April, 1998.

1 B. Reason for Change (License Amendment Request Number 95-0018): 1 l

The proposed changes would add a new TS definition 1.42, defining a

" Refueling Interval" as a period of time < 730 days, and make associated changes to TS Bases 4.0.2, Applicability. The proposed changes would also modify the presently specified 18 month surveillance frequencies in TS Surveillance Requirement (SR) 4.6.2.1.b and SR 4.6.3.1.2 to new specified frequencies of once each Refueling Interval. These changes are in accordance with the NRC guidance provided by Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," and will support conversion of the DBNPS from an 18 month to a 24 month fuel cycle.

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

Docket Number 50-346 License Number NPF-3 Serial Number 2342 Attachment SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 95-0018 (27 pages follow) '

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s s LAR 95-0018 Page 1 SAFETY ASSESSMENT AND SIGNIFICANT HAZARD CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 95-0018 TITLE:

Proposed Modification to the Davis-Besse Nuclear Power Station Unit Number 1, Facility Operating License NPF-3, Appendix A, Technical Specifications to Revise Technical Specification (TS) 1.0, Definitions; TS Bases 3/4.0, Applicability; TS 3/4.6.2.1, Containment Systems - Depressurization and Cooling Systems - Contain-ment Spray System; and TS 3/4.6.3.1, Containment Systems - Containment Isolation Valves.

DESCRIPTION:

The Davis-Besse Nuclear Power Station (DBNPS) Unit No. 1 is converting from an 18 month to a 24 month fuel cycle. This conversion will allow the DBNPS to operate at full power for a longer period of time between refueling outages. In order to support this conversion, it is necessary that the DBNPS Operating License NPF-3, Appendix A, Technical Specifications be amended to change 18 month interval Surveillance Requirements to 24 month interval Surveillance Requirements. In addition, the continued application of TS 4.0.2, which allows curveillance intervals to be increased up to 25% on a non-routine basis, will allow a 24 month surveillance interval to be extended up to 30 months. ,

License Amendment Request Number 95-0018 addresses only a portion of the scope of changes required for the 24 month cycle conversion. Additional required Technical Specification changes will be submitted under separate license amend-ment applications. Associated changes to the DBNPS Updated Safety Analysis Report (USAR), including the Chapter 15 Accident Analysis, are being evaluated under the 10 CFR 50.59 process. In accordance with 10 CFR 50.59, should this evaluation detemine that an unreviewed safety question exists, the USAR changes would be submitted for NRC approval under the license amendment application process.

The NRC guidance provided by Generic Letter 91-04, " Changes in Technical Speci-fication Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991, was utilized in the preparation of this Safety Assessment and Significant Hazards Consideration. Consistent with this guidance, the phrase

'at least once per 18 months, during shutdown" is proposed to be replaced with

• at least once each REFUELING INTERVAL," where applicable. REFUELING INTERVAL is being defined as 'a period of time s 730 days." The restriction 'during chutdown' is being deleted in accordance with Generic Letter 91-04 wherein the NRC staff concluded that the TS need not restrict surveillances as only being performed during shutdown, and that licensees are to give proper regard for performing refueling interval surveillances during power operation or during another mode that is consistent with the safe conduct of that surveillance.

This Safety Assessment and Significant Hazard Consideration (SASHC) proposes the revision of several such Surveillance Requirements. These Surveillance Require-ments are individually described in the enclosures to this SASHC.

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LAR 95-0018 Page 2 In addition, this SASHC proposes the following changes:

-Addition of a new TS definition 1.42, defining a " Refueling Interval" as a period of time s 730 days.

-Addition of a paragraph to TS Bases 4.0.2, Applicability, to read:

The allowable tolerance for performing surveillance activities also provides flexibility to accommodate the length of a fuel cycle for surveillances that are specified to be performed at least once each REFUELING INTERVAL. It is the intent that REFUELING INTERVAL surveillances be performed in an OPERATIONAL MODE consistent with safe plant operation.

Each change is described in further detail below. Each of the proposed changes is also shown on the attached marked-up Operating License pages.

l SYSTEMS, COMPONENTS, AND ACTIVITIES AFFECTED:

The basic activity affected by these proposed revisions is the performance of certain surveillance tests on a 24 month frequency instead of an 18 month 4 frequency. The enclosures to this SASHC identify the specific systems and l components affected by the individually proposed Surveillance Requirement j revisions.

FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS, AND ACTIVITIES:

The enclosures to this SASHC describe the functions performed by the affected systems, components, and activities. 1 EFFECTS ON SAFETY: i The enclosures to this SASHC describe the effects on safety due to increasing certain surveillance test intervals from 18 to 24 months and the continued spplication of TS 4.0.2 (which allows surveillance intervals to be increased  ;

up to 25% on a non-routine basis). Historical surveillance test data and maintenance records were reviewed in evaluating the effect on safety. In cddition, the licensing basis was reviewed for each proposed revision to  ;

cnsure it was not invalidated.

Based on the results of these reviews, it is concluded that there is no adverse cffect on plant safety due to increasing the surveillance test intervals from 18 to 24 months and the continued application of TS 4.0.2. In addition, the licensing basis remains valid.

Manufacturer or vendor maintenance information for the affected components is considered in the DBNPS Preventive Maintenance (PM) Program. The PM Program is being evaluated as a separate activity in support of the conversion from an 18 month to a 24 month fuel cycle. Changes will be made, as necessary, in the PM Program to facilitate a 24 month fuel cycle.

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LAR 95-0018 Page 3 I i

The proposed change to TS 1.0, adding a definition for " Refueling Interval," and the associated proposed change to TS Bases 3/4.0, are administrative changes associated with the 24 month cycle conversion. These changes will have no adverse effect on plant safety. 1 SIGNIFICANT HAZARDS CONSIDERATION:

The Nuclear Regulatory Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazard exists due to a proposed amendment to an Operating License for a facility. A proposed amendment involves no signifi-cant hazards consideration if operation of the facility in accordance with the proposed changes would: (1) Not involve a significant increase in the probabil-ity or consequences of an accident previously evaluated; (2) Not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Not involve a significant reduction in a margin of safety.

Toledo Edison has reviewed the proposed changes and determined that a signifi-cant hazards consideration does not exist because operation of the Davis-Besse Nuclear Power Station, Unit No. 1, in accordance with these changes would:

la. Not involve a significant increase in the probability of an accident previously evaluated because no such accidents are affected by the proposed revisions to increase the surveillance test intervals from 18 to 24 months i for the containment spray system (Surveillance Requirements 4.6.2.1.b), or the containment isolation valves (Surveillance Requirements 4.6.3.1.2).

The proposed change to TS 1.0, adding a definition for " Refueling Inter-val," and the associated proposed change to TS Bases 3/4.0, are administra-tive changes associated with the 24 month cycle conversion. Initiating conditions and assumptions remain as previously analyzed for accidents in the DBNPS Updated Safety Analysis Report.

These revisions do not involve any physical changes to systers or components, nor do they alter the typical manner in which the systems or components are operated.

A review of historical 18 month surveillance data and maintenance records support an increase in the surveillance test intervals from 18 to 24 months (and up to 30 months on a non-routine basis) because no potential for a' significant increase in a failure rate of an affected system or component was identified during these reviews.

These proposed revisions are consistent with the NRC guidance on evaluating and proposing such revisions as provided in Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Puel Cycle," dated April 2, 1991.

Ib. Not involve a significant increase in the consequences of an accident previously evaluated because the source term, containment isolation or radiological releases are not being changed by these proposed revisions.

Existing system and component redundancy is not being changed by these

LAR 95-0018 Page 4 proposed changes. Existing system and component operation is not being changed by these proposed changes. The assumptions used in evaluating the radiological consequences in the DBNPS Updated Safety Analysis Report are not invalidated.

A review of historical 18 month surveillance data and maintenance records support an increase in the surveillance test intervals from 18 to 24 months (and up to 30 months on a non-routine basis) because no potential for a significant increase in a failure rate of an affected system or component was identified during these reviews.

2. Not create the possibility of a new or different kind of accident from any accident previously evaluated because these revisions do not involve any physical changes to systems or components, nor do they alter the typical manner in which the systems or components are operated. A review of historical 18 month surveillance data and maintenance records support an increase in the surveillance test intervals from 18 to 24 months (and up to 30 months on a non-routine basis) because no potential for a significant increase in a failure rate of a system or component was identified during these reviews. No changes are being proposed to the type of testing currently being performed, only to the length of the surveillance test interval.

3. Not involve a significant reduction in a margin of safety because a review of the hist'orical 18 month surveillance data and maintenance records identified no potential for a significant increase in a failure rate of a system or component due to increasing the surveillance test interval to 24 )

months. Existing system and component redundancy is not being changed by  !

these proposed changes.

l There are no new or significant changes to the initial conditions contri- l buting to accident severity or consequences. Therefore, there are no i significant reductions in a margin of safety. l CONCLUSIONS:

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 involves 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.

ATTACHMENT:

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

Also attached are summaries of the licensing basis, surveillance data, and maintenance record reviews for Surveillance Requirement 4.6.2.1.b (Enclosure 1) and for Surveillance Requirement 4.6.3.1.2 (Enclosure 2).

I 4 LAR 95-0018 Page 5

REFERENCES:

1. Davis-Besse Nuclear Power Station (DBNPS) Unit No. 1, Operating License NPF-3, Appendix A, Technical Specifications, through Amendment 211.

2. DBNPS Updated Safety Analysis Report,.through Revision 19.

3. Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991.

4. 10 CFR 50.59, " Changes, Tests, and Experiments."

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