ML20148J715

Forwards Request for Addl Info Re Proposed Tech Spec Change to Delete Safety Features Actuation Signal to Certain Valves

ML20148J715
Person / Time
Site:	Davis Besse
Issue date:	03/24/1988
From:	De Agazio A Office of Nuclear Reactor Regulation
To:	Shelton D TOLEDO EDISON CO.
References
DB-88-014, DB-88-14, TAC-65685, TAC-65686, NUDOCS 8803300356
Download: ML20148J715 (4)

Text

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, s March 24, 1988 Docket No. 50-346 Distribution Serial No. DB-88-014 -> Docket File < 0GC-WF1

'NRC & Local'PDRs E. Jordan PDIII-3 r/f JPartlow GHolahan KEPerkins PKreutzer ACRS(1)

Mr. Donald C. Shelton ADe Agazio PDIII-3 g/f-Vice President - Nuclear Toledo Edison Company Edison Plaza - Stop 712 300 Madison Avenue Toledo, Ohio 43652

Dear Mr. Shelton:

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SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (TAC 65685) l l

We have received and are reviewing your letter dated March 21, 1988 (No.1500), containing supplemental information related to your applic-ation for license amendment dated August 7,1987 (No.1400). This information was submitted in response to our March 3,1988, conference call. Subsequent to that conference call, we have determined the need for further additional information. The attachment to this letter identifies the information required.

The information requested affects fewer than ten respondents; therefore, OMB clearance pursuant to PL 95-511 is not required. Please provide your response to this request not later than April 30, 1988.  !

Sincerely, j b i Albert W. De Agazio, Project Manager j Project Directorate III-3 l Division of Reactor Projects - III, IV, V & Special Projects

Enclosure:

i As stated i cc: See next page OFFICE ,

Office: LA/P I -3 PM/PDIl PD P III-Surname: PKre zer ADe Agazio/rl KEPerkins Date: 03/ /87 03/g /87 03/g47/87 i 56 800324 l

$$033jjjCK05000346 P

PDR

s Mr. Donald C. Shelton Davis-Besse Nuclear Power Station Toledo Edison Company Unit No. 1 cc:

Donald H. Hauser, Esq.

The Cleveland Electric Radiological Health Program Illuminating Company Ohio Department of Health P. O. Box 5000 1224 Kinnear Road Cleveland, Ohio 44101 Columbus, Ohio 43212 Mr. Robert W. Schrauder Attorney General Manager, Nuclear Licensing Department of Attorney Toledo Edison Company General Edison Plaza 30 East Broad Street 300 Madison Avenue Columbus, Ohio 43215 Toledo, Ohio 43652 Mr. James W. Harris, Director Gerald Charnoff, Esq. (Addressee Only)

Shaw, Pittman, Potts Division of Power Generation and Trowbridge Ohio Department of Industrial Relations 2300 N Street N.W. 2323 West 5th Avenue Washington, D.C. 20037 P. O. Box 825 Columbus, Ohio 43216 Regional Administrator, Region III U.S. Nuclear Regulatory Comission Ohio Environmental Protection Agency 799 Roosevelt Road 361 East Broad Street Glen Ellyn, Illinois Columbus, Ohio 43266-0558 President, Board of Mr. Robert B. Borsum County Comissioners of Babcock & Wilcox Ottawa County Nuclear Power Generation Division Port Clinton, Ohio 43452 Suite 525, 1700 Rockville Pike Rockville, Maryland 20852 State of Ohio Public Utilities Comission Resident Inspector 180 East Broad Street U.S. Nuclear Regulatory Comission Columbus, Ohio 43266-0573 5503 N. State Route 2 Oak Harbor, Ohio 43449 0

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Enclosure

, =, s REQUEST FOR ADDITIONAL INFORMATION PLANT SYSTEMS BRANCH DAVIS BESSE PROPOSED TECHNICAL SPECIFICATION CHNAGE TO DELETE SFAS TO CERTAIN VALVES (TAC NO. 65685) .

The following information is required in order for the staff to complete its review of the submittal by the Toledo Edison Company, dated August 7, 1987:

1. The proposed changes to the plant Technical Specifications (TS) in the licensee's letter dated August 7, 1988 will revise Table 3.3-5 Safety Features System Response Times to delete reference to the main steam warmup drain valves and atmospheric vent valves (AVV) receiving a high containment pressure or low reactor coolant system pressure SFAS automatic signal. It was indicated that the purpose of this change was to improve reliability and availability of the Main Feedwater System by reducing the chance of plant trips  !

resulting from an inadvertent SFAS. The primary justification for this change was that those valves are normally closed during power  :

operations. The SFAS signal serves to provide only a backup to l procedural requirements for maintaining the valves in a closed ,

position. l l

The staff has two concerns with the above proposed TS change: l (1) These valves are normally closed, and an automatic closure  !

of these valves does not isolate the feedwater system. Therefore, how can the elimination of the SFAS automatic signal for MS warmup drain valves and AVVs improve reliability of the main feedwater system?

(2) It is required in NUREG-0737 Item II.E.4.2 that following an j accident all nonessential systems penetrating containment be auto- 1 matica11y isolated. No credit can be given for operator action. i Py eliminating the SFAS state how this requirement is satisfied, or l justify why those containment isolation valves can be granted a l deviation from this requirement.

2. The proposed TS change will revise TS 3/4.3.2, Table 3.3-5 to delete reference to the atmospheric vent valves, main steam warmup drain valves, main steam isolation valves, main feedwater stop valves, and main steam line warmup valves receiving a manual SFAS. It was indicated in a telecon of March 3, 1988 between the licensee and staff that 4

those valves were also listed in Table 3.6-?, Containment Isolation Valves, under TS section 3/4.6.3. Therefore, the licensee considered it redundant and unnecessary to list those valves in Table 3.3-5.

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The staff finds that the surveillance requirements under TS 3/4.3.2 are not the same as the requirements under TS 3/4.6.3. For example a monthly CHANNEL FUNCTIONAL TEST is required by TS 3/4.3.7 but not required by TS 3/4.6.3. Identify the differences between these .

TS requirements and ,iustify your proposed TS for the above valves.

3. The proposed change will revise TS section 3/4.3.6 Table 3.6-2 to delete isolation time requirements for the MSIV, MS wannup valves, MFW stop valves, AVV, MS warmup drain valves, and steam generator blowdown valves, along with the deletion of SFAS actuation. The licensee's evaluation of unreviewed safety questfor, has been focused on large break LOCA and MSLB. The licensee should verify whether there are any other uniden.tified safety concerns or accident analyses ,

that may be impacted by the proposed chances? For example, confirm the dose consequences for a steam generator tube rupture accident sre  !

within acceptable limits. Confirm that the environmental effects for  !

a small MSLB inside or outside containment are not adversely afft. ted.

Verify that the small break LOCA accident analysis is not advers7:1y affected by the proposed change. Provide additional discussion .2nd/or analysis to justify that there is no unreviewed safety question resulting from the proposed change.

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