ML20117N844
| ML20117N844 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/12/1996 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | |
| Shared Package | |
| ML20117N842 | List: |
| References | |
| 2382, NUDOCS 9609200121 | |
| Download: ML20117N844 (8) | |
Text
Dockst Number 50-346 Licance Numbar.NPF-3
~Ssrial Number 2382 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 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 2382) concern:
l Appendix A, Technical Specifications (TS):
'3/4.1.3.4 Reactivity Control Systems - Rod Drop Time 3/4.5.2' Emergency Core Cooling Systems - Tavg > 280*F.
By:
b J. K. Y od,Vice President'- Nuclear Sworn to and subscribed before me this 12th day of September, 1996.
N*L
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c NotaryPublic,[Stateof' Ohio l:
My commission expires September 3, 1997.
Nora Lynn Flood a
l-9609200121 960912 PDR ADOCK 05000346; P
PDR '
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Docket Number 50-346 License Numbar NPF-3 Sarial Numbar 2382 Enclosure PAge 2 The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1 Operating License Number NPF-3, Appendix A, Technical Specification (TS) 3/4.1.3.4, Reactivity Control Systems - Rod Drop Time, and TS 3/4.5.2, Emergency Core Cooling Systems - Tavg > 280*F.
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 11RFO is presently scheduled to commence in April, 1998.
B.
Reason for Change (License Amendment Request Number 95-0023):
The proposed changes would modify the presently specified 18 month surveillance frequencies in TS surveillance frequencies in TS Surveillance Requirement (SR) 4.1.3.4.c and SR 4.5.2.b 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.
The proposed changes would also modify TS SR 4.5.2.b to remove a footrote which is no longer applicable.
l C.
Safety Assessment and Significant Hazards Consideration:
See Attachment.
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Dockst Numbzr 50-346 License Number NPF-3 Serial Number 2382 Attachment i
l SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 95-0023 (24 pages follow) 4
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LAR 95-0023 Page 1 SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR i
LICENSE AMENDMENT REQUEST NUMBER 95-0023 j
1 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) 3/4.1.3.4, Reactivity Control Systems - Rod Drop Time, and TS 3/4.5.2, Emergency Core Cooling Systems -
Tavg > 280*F.
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
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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 surveillance intervals to be increased up to 25%
j on a non-routine basis, will allow a 24 month surveillance interval to be extended up to 30 months.
License Amendment Request (LAR) Number 95-0023 addresses only a portion of the scope of changes required for the 24 month cycle conversion.
i Additional required Technical Specification changes will be submitted under l
separate license amendment 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 determine 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 Specification Sarveillance 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 proposed by a separate license amendment application (LAR 95-0018; DBNPS letter Serial Number 2342) to be defined as "a period of time < 730 days."
The restriction "during shutdown" 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.
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LAR 95-0023 Page 2 j.
This Safety Assessment and Significant Hazard Consideration (SASHC) r proposes the revision of several such Surveillance Requirements. These Surveillance Requirements are individually described in the enclosures to this SASHC.
t This SASHC also proposes a modification to Surveillance Requirement (SR) 4 4.5.2.b to remove a time-conditional footnote which has expired.
Each change is described in further detail below. Each of the proposed changes is also shown on the attached marked-up Operating License pages.
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 frequency. The enclosures to this SASHC identify the specific systems or components affected by the individually proposed Surveillance Requirement 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.
EFFECTS ON SAFETY:
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 application 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 addition, the licensing basis was reviewed for each proposed revision to ensure it was not invalidated.
Based on the results of these reviews, it is concluded that there is no adverse effect 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.
The proposed change to TS SR 4.5.2.b to remove a time-conditional footnote j
which has expired is an administrative change and will have no adverse effect on plant safety.
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LAR 95-0023 Page 3 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 significant hazards consideration if operation of the facility in accordance with the proposed changes would: (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 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 significant 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 for the reactivity control systems (Surveillance Requirement 4.1.3.4.c), or the emergency core cooling systems j
(Surveillance Requirement 4.5.2.b), or the proposed administrative change to Surveillance Requirement 4.5.2.b to remove a time-conditional footnote which has expired.
Initiating conditions and assumptions remain as previously analyzed for all accidents in the DBNPS Updated Safety Analysis Report.
l 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 an affected system or component was identified during these reviews.
j 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 Fuel 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 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.
LAR 95-0023 Page 4 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
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involve any physical changes to systems or components, nor do they alter the typical manner in which the systems or components are opera-ted.
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 historical 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 and operation is not being changed by these proposed changes.
There are no new or significant changes to the initial conditions contributing to accident severity or consequences. Therefore, there are no significant reductions in a margin of safety.
CONCLUSIONS:
On the basis of the above, Toledo Edison has determined that the License
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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 4.1.3.4.c (Enclosure 1) and for Surveillance Requirement 4.5.2.b (Enclosure 2).
LAR 95-0023 Page 5
REFERENCES:
1.
Davis-Desse Nuclear Power Station (DDNPS) 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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