ML20138M116
| ML20138M116 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/14/1997 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20138M120 | List: |
| References | |
| NUDOCS 9702250269 | |
| Download: ML20138M116 (3) | |
Text
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GQ 6501 N. State Route 2 419-249-2300 John K. Wood Oak Haroor, OH 43449 FAX: 419-3218337 Vce Presdent -Nuclear Davis-Besse Docket Number 50-346 License Number NPF-3 Serial Number 2448 February 14, 1997 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001
Subject:
License Amendment Application to Revise Technical Specifications Regarding Decay Heat Removal System Valve Pit Surveillance Requirements (License Amendment Request No. 97-0006)
Gentlemen:
Enclosed is an application for an amendment to the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1 Operating License Number NPF-3, Appendix A, Technical Specifications, to reflect the changes attached. The proposed changes involve Technical Specification (TS) 3/4.5.2, Emergency Core Cooling Systems - ECCS Subsystems - T
>280*F, and associated Bases 3/4.5.2 and 3/4.5.3, ECCS Subsystems.
Technical Specification (TS) 3.5.2 requires two independent Emergency Core Cooling Systems (ECCS) Subsystems to be operable.
Surveillance Requirement (SR) 4.5.2.f requires each ECCS Subsystem to be demonstrated operable by performing a vacuum leakage rate test of the watertight enclosure for valves DH-11 and DH-12 that assures the motor operators on valves DH-11 and DH-12 will not be flooded for at least seven (7) days following a Loss-of-Coolant Accident (LOCA). The test is required to be performed:
(1) At least once per 18 months, (2) After each opening of the watertight enclo-sure, and (3) After any maintenance on or modification to the watertight enclosure which could affect its integrity. These SRs ensure that, at a minimum, the assumptions used in the safety analyses are met and that subsystem operability is maintained. Surveillance Requirements for the watertight enclosure provide assurance that a circulation flow path will be maintained as described in Updated Safety Analysis Report (USAR)Section I
6.3.3.1.2, "Results of Analysis (Large Break)."
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9702250269 970214 PDR ADOCK 05000346 P
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Dockst Number 50-346 Licenna Number NPF-3 Serial Number 2448
,Page 2 During 1986 s plant modification was performed to the decay heat valve pit to install level switches and to add an inspection port.
The purpose of this modification was to provide the capability to detect and confirm leakage in the valve pit during plant operation. The plant modification took into account that due to its design features, the opening and closing of the inspection port would not require performance of SR 4.5.2.f.
On February 11, 1997, a Potential Condition Adverse to Quality Report (PCAQR) was initiated by the DBNPS Staff to document a literal compliance concern regarding whether opening and subsequent closure of the decay heat valve pit inspection port constitutes a breach of the decay heat valve pit
" watertight enclosure," hence requiring performance of SR 4.5.2.f.
As a conservative measure, both trains of ECCS were declared inoperable and TS 3.0.3, which requires a plant shutdown to be commenced within one hour, was entered on February 12, 1997 at 0915 hours0.0106 days <br />0.254 hours <br />0.00151 weeks <br />3.481575e-4 months <br />. However, TS 4.0.3, which allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for delaying the actions of TS 3.0.3 in order to provide time for completion of the surveillance, was also entered.
It was determined at 1435 hours0.0166 days <br />0.399 hours <br />0.00237 weeks <br />5.460175e-4 months <br /> that SR 4.5.2.f could not be performed at power.
TS 4.0.3 was exited, and a plant shutdown was commenced from 100% rated thermal power on February 12, 1997 at 1521 hours0.0176 days <br />0.423 hours <br />0.00251 weeks <br />5.787405e-4 months <br /> in accordance with TS 3.0.3.
While the plant shutdown was proceeding, contacts were made with NRR and Region III Staff to request enforcement discretion to allow suspension of the plant shutdown. Enforcement discretion was verbally granted on February 12, 1997 at 2005 hours0.0232 days <br />0.557 hours <br />0.00332 weeks <br />7.629025e-4 months <br />, at which time the plant was in Mode 1 at approximately 10% rated thermal power. A follow-up letter providing documentation relative to the February 12 verbal request for enforcement diccretion was submitted to the NRC on February 13, 1997 (TE Serial Number 2449).
The proposed changes are being submitted as a follow-up emergency license amendment application in the manner allowed by 10 CFR 50.91(a)(5) to avoid a shutdown of the DBNPS, absent the existing enforcem?nt discretion.
However, with the enforcement discretion presently in force, Toledo Edison is amenable to the NRC processing this application as an exigent application or a normal application.
Absent the existing NRC's granted enforcement discretica, an emergency situation exists as described in 10 CFR 50.91(a)(5), in that not approving the proposed license amendment in a timely manner would result in a shutdown of the DBNPS. As described in the enclosed Safety Assessment and Significant Hazards Consideration (SASHC), the proposed license amendment does not involve a significant hazards consideration.
As also described in the enclosed SASHC, the situational conflict which exists between SR 4.5.2.f and the use of the inspection port in Modes 1, 2,
or 3 was first identified as a literal compliance issue by Toledo Edison on February 11, 1997, with the plant at 100% rated thermal power. Therefore, this created the emergency situation whereby a plant shutdown would be required absent enforcement discretion or an emergency license amendment.
Dockst Number 50-346 Licenza Number NPF-3 Serial Number 2448
.Page 3 Toledo Edison has performed the attached environmental assessment and determined that the proposed amendment, if approved, will have no significant impact on the environment or irreversible environmental consequences.
Should you have any questions or require additional information, please contact Mr. James L.
Freels, Manager - Regulatory Affairs, at (419) 321-8466.
Very truly yours, 8-
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MF / 3 Enclosure cc:
A.
B. 3each, Regional Administrator, NRC Region III A. G. Hansen, NRC/NRR Project Manager S.
Stasek, NRC Region III, DB-1 Senior Resident Inspector J. R. Williams, Chief of Staff, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
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