ML20151E354

Application for Amend to License NPF-3,changing Tech Specs Re Startup Feedwater Pump Sys & Auxiliary Feedwater Sys

ML20151E354
Person / Time
Site:	Davis Besse
Issue date:	07/15/1988
From:	Shelton D TOLEDO EDISON CO.
To:
Shared Package
ML20151E352	List: ML20151E350 ML20151E354 ML20151E357
References
1489, NUDOCS 8807260034
Download: ML20151E354 (17)

Text

- x ,

, 4 1 l

h- 'Dpckst.No. 50-346 License No.~ NPF-3 Serial No. 1489 Enclosure 4

APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POVER STATION UNIT N0. 1 9

Attached are requested changes to the' Davis-Besse Nuclear Power Station, Unit No. 1 Facility Operating License No. NPF-3. Also included are the Safety Evaluation and Significant Hazards Consideration.

The proposed changes (submitted under cover letter Serial No. 1489) concern License Condition 2.C.(3)(t), Startup Feedvater Pump System; Technic"' Specification 3/4.7.1.2, Auxiliary Feedvater System; and Basis 3/4.7.1.2, Auxiliary Feedvater System.

By D. C. Shelton, Vice President, Nuclear c'

Sworn and subscribed before me this 15thday of July,1988.

N

( LLLh LL Notary Public, State of Ohio LAURIE A.HIMLE Motary Public. State at Ohio

'- My Commission Empires May 15.1991 ,

8807260034 880715 PDR ADOCK 05000346 P PDC

9 -:

" ^

• i Docket No. 50-346-

_ ,. LJeansa No. NPF-3 ~

Serial No. 1489

-Enclosure Page 2 The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power-Station, Unit No. 1 Operating License No. NPF-3, Appendix A, Technical Specifications.

A .' Time required to Implement: This change vill be implemented within 45 days after issuance of the License Amendment.

B. Reason for Change: (LAR No.,88-001): Replace the Startup Feedvater Pump License Condition 2.C.(3)(t) vith Surveillance Requirement 4.7.1.2.a.4 and include a revision to the Basis Section, and clarify Specification 4.0.4 applicability to the AFV System Surveillance Requirements.

C. Safety Evaluation: See attached Safety Evaluation (Attachment No. 1).

D. Signification Hazards Consideration: .See attached Significant Hazards 4 Consideration (Attachment No. 2).

P 4

I

e Dockst No 50 3$6

. Licensa No. NPF-3 Serial No. 1489

-Attachment 1 Page 1 SAFETY EVALUATION 1

DESCRIPTION OF THE PROPOSED ACTIVITY The purpose of this Safety-Evaluation is to review proposed changes to the Davis-Besse Nuclear Power Station Unit No. 1 Operating License, Appendix A.

1 Technical Specifications. . The proposed changes involve replacing the Startup Feedvater Pump (SUFP) License Condition 2.C.(3)(t).vith a Surveillance Requirement and associated Basis change, and clarifying when the provisions of Specification 4.0.4 are not applicable for the. Auxiliary Feedvater (AFW)

Surveillance Requirements.

In January 1985, License Condition 2.C.(3)(t) was imposed on the SUFP after it. ,

was determined that non-seismic /high energy and moderate energy SUFP/ Turbine '

Plant Cooling Vater (TPCV) piping failures could potentially jeopardize.

operation of the Auxiliary Feedvater Pumps (AFP). License Condition 2.C.(3)(t).(Attachment I) imposed operational restrictions on the SUFP. These restrictions included: 1) stationing an operator in the SUFP/AFP area during SUFP operation; 2) isolating the SUFP and TPCV piping outside the SUFP/AFP area; and 3) installing a new SUFP. prior to Cycle 6 operation.

In 1986, electrical power to the.SUPP motor was removed and the SUFP was functionally replaced with a Motor Driven Feedvater Pump (MD'/P). The MDFP was installed outside of the AFP rooms to be used during plant s03rtups and shutdowns and as an additional source of feedvater in the event the Main Feedvater Pumps (MFP) and the steam turbine driven AFPs failed.

During the fifth refueling outage, the SUFP vill be repovered to provide an '

additional means to remove decay heat via the steam generators. It vill be 4

locally operated and vill not be used in Modes 1, 2 and 3, when the AFPs are required to be operable, unless other efforts have failed to re-establish

, feedvater using the MFPs, steam turbine driven AFPs and the HDFP. The SUFP/TPCV lines, which isolate the SUFP outside of the AFP rooms, vill be valved closed h. Modes 1, 2 snd 3, thereby4 removing the potential hazard to the AFPs by SUFr operation. Tlent procedures will provide cperator instructions for placing the SUFP in service in the unlikely event that both MFPs, both AFPs and the MDFP fail.

Since the SUFP vill not be used (unless  :

the above conditions are encountered) in Modes 1, 2, and 3 (when the AFPs are required to be operable), the concern for SUFP and TPCV pipe failures in the AFP rooms vill be eliminated.

This request proposes deleting License Condition 2.C.(3)(t) and incorporating Item 2 of License Condition 2.C.(3)(t) as Technica1' Specification Surveillance Raquirement 4.7.1.2.a.4. The AFV System Basis is also being revised to reflect this change. Additionally, Toledo Edison proposes clarifying when the provisions of Specification 4.0.4 are not applicable for the AFV Surveillance Requirements.

P

Dockst No. 50-346

, bietnse No. NPF-3 Serial No. 1489 Attachment 1 Page 2 DOCUMENTS AFFECTED ST 5071.14, Auxiliary Feedvater Train 1 Monthly Valve Verification ST 5071.24, Auxiliary Feedvater Train 2 Monthly Valve Verification SP 1106.27, Startup Feedvater Pump Operating Procedure EP 1202.01, RPS, SFAS, SFRCS or SG Tube Rupture Emergency Procedure AD 1838.00, Surveillance and Periodic Test Program SYSTEMS AND COMPONENTS AFFECTED Main Feedvater (MFV) System Auxiliary Feedvater (AFV) System Motor Driven Feedvater Pump (HDFP) System Startup Feedvater Pump (SUFP) System SAFETY FUNCTIONS OF SYSTEMS AFFECTED The MFV System supplies the normal source of feedvater to the steam generators. It provides the steam generators with enough vater to replace the steam leaving the units.

Tb safety function of AFV System is to supply feedvater to the steam

.. erators for the removal of reactor decay heat in the absence of NFV and/or to promote natural circulation of the Reactor Coolant System in the event all four reactor coolant pumps fail, i

The functior, of the MDFP System during routine plant operation is to provide i feedvater to the steam generators during startups and shutdowns. The MDFP l alse serves the function of providing a diverse means of supplying AFV to the steam generators as a backup to the steam turbine driven AFPs. The HDFP may be aligned to the MFV System at or belov 40% power and is aligned to the AFV System above 40% power.

The SUFP vill serve no safety function. It was used as part of the original l plant design, during startup and shutdown when insufficient steam was available to drive the MFPs. However, operation was limited by License Condition 2.C.(3)(t) after it was determined tht.t piping failures could jeopardize the AFPs. In the new configuration, the SUFP vill not be used in Modes 1, 2 or 3, when the AFPs are required to be operable, unless other efforts have failed to re-establish feedvater using the MFPs, the steam  ;

turbine driven AFPs and the MDFP. Surveillance Requirement 4.7.1.2.a.4 vill '

require isolation of the SUFP suction, discharge and cooling water lines,  !

thereby eliminating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms when the AFPs are required to be operable. Since the AFPs are not required to be operable in Modes 4, 5 and 6, the SUFP may be used in Modes 4, 5 and 6. I EFFECTS ON SAFETY License Condition 2.C.(3)(t) vas added in January 1985 by License Amendment No. 83 (Log No. 1672). Since that time, Toledo Edison has installed the MDFP to provide an additional, redundant source of feedvater. The MDFP is located outside of the AFP rooms, thereby removing the hazards to the AFPs. The MDFP l

1 w,,

I Dockat No. 50-346

, Liccns2 No. NPF-3 Serial No. 1489 Attachment 1 Page 3 is used during normal plant operation for startup and shutdown. Toledo Edison is repovering the SUFP to provide an additional means to renove decay heat via the steam generators. The SUFP is not to be used in Modes 1, 2 or 3, unless other efforts have failed to re-establish feedvater using the NFPs, the steam turbine driven AFPs and the HDFP. Since the proposed Surveillance Requirement vill prevent SUFP operation in Modes 1, 2 or 3, the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms vill be eliminated when the AFPs are required to be operable.

Each item of License Condition 2.C.(3)(t) is discussed below.

Item 1 of License Condition 2.C.(3)(t) requires Toledo Edison to station an operator in the SUFP/AFP area during operation of the SUFP to monitor the SUFP/TPCV piping in the AFP rooms. In the event of a SUFP/TPCV pipe leakage, a

the operator vill trip the SUFP locally or notify the Control Room to trip the SUPP and isolate the SUFP/TPCV piping.

The SUFP vill not be used in Modes 1, 2 or 3, when the AFPs are required to be operable, unless other efforts have failed to re-establish feedvater using the HFPs, the steam turbine driven AFPs and the HDFP. Surveillance Requirement 4.7.1.2.a.4 vill require isolation of the SUFP suction, discharge and cooling vater lines, thereby eliminating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms when the AFPs are required to be operable. Thus, there is no longer a concern to have an operator stationed in the SUFP/AFP area to isolate the SUFP/TPCV piping to eliminate an AFP room flooding hazard. Since the AFPs are not required to be operable in Modes 4, 5 and 6, the SUFP may be used in Modes 4, 5 and 6. Also, because the SUFP vill not be used when the AFPs are required to be operable, i.e., in Modes 1, 2 and 3, the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms vill be eliminated. Toledo Edison therefore proposes deleting Item 1 of License Condition 2.C.(3)(t).

Item 2 of License Condition 2.C.(3)(t) requires Toledo Edison to isolate and maintain isolation outside the SUFP//FP area of the SUFP suction, discharge and TPCV piping when the SUFP is not in operation (Modes 1, 2 and 3).

In conjunction with returning electrical power to the SUFP motor, Toledo Edison proposes to isolate and maintain isolation of the SUFP/AFP area.

Isolation vill be verified through an additional Technical Specification Surveillance Requirement. Surveillance Requirement 4.7.1.2.a.4 vill be added to the AFV System Technical Specification and vill require verifying, on a 31-day staggered test basis, for each AFV train, that the TPCV valves (CV196 and CV197), the SUFP suction valves (FV32 and FV91) and the SUFP discharge valve (FV106) are closed (see Attachment II). By maintaining these valves closed, the SUFP/TPCV lines located in the AFP rooms vill be isolated, thereby negating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms when the AFPs are required to be operable. Toledo Edison also proposes to add to the Basis the explanation that by verifying these valves are closed, concerns associated with pipe failures in the AFP rooms are addressed. Toledo Edison therefore proposes deleting Item 2 of License Condition 2.C.(3)(t) and incorporating Technical Specification Surveillance Requirement 4.7.1.2.a.4 in the AFV System Technical Specification.

Dock 0t No. 50-346 Lic;nsa No. NPF-3 Serial No. 1489 Attachment 1 Page 4 Item 3 of License Condition 2.C.(3)(t) requires that Toledo Edison install a SUFP, associated piping and valves to remove the hazards to the AFPs prior to commencing Cycle 6.

Consistent with the intent of Item 3 of License condition 2.C.(3)(t), Toledo Edison has installed the MDFP. The MDFP is located outside of the AFP rooms, thereby removing the hazards to the AFPs. Toledo Edison is repovering the SUPP as an additional source of feedvater. However, since the SUFP vill not be used in Modes 1, 2 or 3 when the AFPs are required to be operable, the hazards to the AFPs vill be eliminated. Therefore, Toledo Edison proposes deleting Item 3 of License Condition 2.C.(3)(t).

Toledo Edison also proposes clarifying when the provisions of Specification 4.0.4 are not applicable for the AFV Surveillance Requirements (SR). The currently written exception is confusing.

An exception to Specification 4.0.4 is necessary for two of the AFV SRs.

Because the AFV System Technical Specification is applicable in Modes 1, 2 and 3, the AFV SRs are required to be performed at the frequencies specified to verify system operability. The SRs are also done when coming up in power, prior to entering Mode 3 from Mode 4, if they have not been performed within the frequencies specified. Performance of two of the AFV SRs however requires the plant to be in Mode 3. SR 4.7.1.2.a.1 requires verifying that each steam turbine driven pump develops a differential pressure of greater than or equal to 1070 psid on recirculation flov vhen the secondary steam supply pressure is greater than 800 psia, i.e. the plant to be in Mode 3. Similarly, SR 4.7.1.2.b.2. requires verifying that each pump starts automatically upon receipt of an AFV actuation test signal which requires the plant to be in Mode 3 to produce a steam generator supply which is adequate to conduct the test, i.e., main steam pressure of greater than or equal to 800 psia. Therefore, these two SRs should be clarified to allow entry into Mode 3, to perform the surveillance, since they cannot be performed in Mode 4, i.e., prior to entering Mode 3, as the Applicability Statement dictates. This can be accomplished by providing an exception to Specification 4.0.4 for entry into Mode 3 for SR 4.7.1.2.a.1 and 4.7.1.2.b.2.

The currently written exception is confusing in that Mode 3 of the Applicability Statement and SR 4.7.1.2.b.2 refer to a footnote at the bottom of the page that says the provision of section 3.0.4 is not applicable for i entry into Mode 3. Specification 3.0.4 states "Entry into an OPERATIONAL MODE or other specified applicability condition shall not be made unless the conditions of the Limiting Condition for Operation are met witheur reliance on provisions contained in the ACTION statements unless otherwise excepted. This l provision shall not prevent passage through OPERATIONAL MODES as required to l comply with ACTION statements" and applies to Limiting Conditions for j Operation. As discussed in Basis section 3.0.4, exceptions to Specification j 3.0.4 are stated in the ACTION statements of the appropriate specifications. '

Specification 4.0.4 states: "Entry into an OPERATIONAL MODE or other l specified applicability condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting condition for Ope-ation have been

]

performed within the stated surveillance interval or as otherwise specified" and applies to Surveillance Requirements (SR). An exemption to Specification 4.0.4 vould permit completion of SRs 4.7.1.2.a.1 and 4.7.1.2.b.2 as it vould l

l j

Dock 2t'Ns. 50-346

, Licensa No. NPF-3 Serial No. 1489 Attachment 1 Page 5 permit entry into Mode 3 from Mode 4 to perform the surveillance test.

Because Specification 3.0.4 applies to Limiting Conditions for Operation and Specification 4.0.4 applies to SRs, Specification 4.0.4 is the appropriate reference for the AFV SRs.

Therefore, this application proposes clarifying that the provisions of Specification 4.0.4 are not applicable, for entry into Mode 3, for SRs 4.7.1.2.a.1 and 4.7.1.2.b.2, as the SRs require the plant to be in Mode 3 to produce a steam generator steam supply which is adequate to conduct the surveillances. The remaining AFV SRs can be performed prior to entering Mode 3, which is required by the Applicability Statement, therefore, no additional clar.ifications regarding Specification 4.0.4 are necessary.

DISCUSSION OF UNREVIEVED SAFETY OUESTION The proposed changes involve deleting License Condition 2.C.(3)(t),

incorporating Item 2 of License Condition 2.C.(3)(t) as Technical Specification Surveillance Requirement 4.7.1.2.a.4, revising the AFV System Basis to reflect this change, and clarifying when the provisions of 4.0.4 are not applicable for the AFV Surveillance Requirements.

Therefore, implementation of these changes vould:

Not increase the probability of an accident previously evaluated in the USAR hecause there vill be no change in the present method of plant operation in Modes 1, 2 and 3. The SUFP vill not be placed in service in Modes 1, 2 and 3, when the AFPs are required to be operable, unless efforts have failed to re-establish feedvater using the MFPs, the steam turbine driven AFPs and the MDFP. Surveillance requirement 4.7.1.2.a.4, instead of License Condition 2.C.(3)(t), vill require isolation of the SUFP suction, discharge and cooling vater lines while the AFPs are required to be operable (Modes 1, 2 and 3),

thereby eliminating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms. Thc proposed changes to the AFV System Technical Specification, regarding the applicability of Specification 4.0.4 to the AFV SRs, simply clarify what exists currently in the AFV Cystem Technical Specification (10CFR50.59(a)(2)(1)).

Not increase the consequences of an accident previously evaluated in the USAR because there vill be no change in the present method of plant operation in Modes 1, 2 and 3. The SUFP vill not be placed in service in Modes 1, 2 and 3, when the AFPs are required to be operable, unless efforts have failed to re-establish feedvater using the MFPs, the steam turbine driven AFPs and the MDFP. Surveillance Requirement 4.6.1.2.a.4, instead of License Condition 2.C.(3)(t), vill require isolation of the SUFP suction, discharge and cooling vater lines while the AFPs are required to be operable (Modes 1, 2 ,

and 3), thereby eliminating the concerns for non-seismic /high energy and 1 moderate energy pipe failures in the AFP rooms. The proposed changes to the AFV System Technical Specification, regarding the applicability of Specification 4.0.4 to the AFV SRs, simply clarify vhat exists currently in j the AFV System Technical Specification (10CFR50.59(a)(2)(1)). '

I l

l

d Dockst Ns. 50-346

, Lic:nsa No. NPF-3 Serial No. 1489 Attachment 1 Page 6 Not increase the probability of a malfunction of equipment important to safety previously evaluated in the USAR because there vill be no change in the present method of plant operation in Modes 1, 2 and 3. The SUFP vill not bo placed in service in Modes 1, 2 and 3, when the AFPs are required to be operable, unless efforts have failed to re-establish feedvater using the MFPs, the steam turbine driven AFPs and the HDFP. Surveillance Requirement 4.7.1.2.a.4, instead of License Condition 2.C.(3)(t), vill require isolation of the SUFP suction, discharge and cooling vater lines while the AFPs are required to be operable (Modes 1, 2 and 3), thereby eliminating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms. The proposed changes to the AFV System Technical Specification, regarding the applicability of Specification 4.0.4 to the AFV SRs, simply clarify what exists currently in the AFV System Technical Specification (10CFR50.59(a)(2)(i)).

Not increase the consequences of a malfunction of equipment important to safety previously evaluated in the USAR because there vill be no change in the present method of plant operation in Modes 1, 2 and 3. The SUFP vill not be placed in service in Modes 1, 2 and 3, when the AFPs are required to be operable, unless efforts have failed to re-establish feedvater using the HFPs, the steam turbine driven AFPs ard the HDFP. Surveillance Requirement 4.7.1.2.a.4, instead of License Condition 2.C.(3)(t), vill require isolation of the SUFP suction, discharge and cooling water lines while the AFPs are required to be operable (Modes 1, 2 and 3), thereby eliminating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms. The proposed changes to the AFV System Technical Specification, regarding the applicability of Specification 4.0.4 to the AFV SRs, simply clarify what exists currently in the AFV System Technical Specification (10CFR50.59(a)(2)(i)).

Not create the possibility for an accident of a different type than any evaluate.J previously in the USAR because there vill be no change in the present method of plant operation in Modes 1, 2 and 3. The SUFP vill not be ,

l placed in service in Modes 1, 2 and 3, when the AFPs are required to be operable, unless efforts have failed to re-establish feedvater using the HFPs, the steam turbine driven AFPs and the HDFP. Surveillance Requirebent 4.7.1.2.a.4, instead of License Condition 2 C.(3)(t), vill require isolation 1

of the SUFP suction, discharge and cooling vater lines while the AFPs are I required to be operable (Modes 1, 2 and 3), thereby eliminating the concerns j for non-seismic /high energy and moderate energy pipe failures in the AFP 1 rooms. The proposed changes to the AFV System Technical Specification, I regarding the applicability of Specification 4.0.4 to the AFV SRs, simply '

clarify what exists currently in the AFV System Technica.1 Specification (10CFR50.59(a)(2)(ii)).

Not create the possibility for a malfunction of a different type thw any evaluated previously in the USAR because there vill be no change in the present method of plant operation in Modes 1, 2 and 3. The SUFP vill c.ot be placed in service in Modes 1, 2 and 3, when the AFPs are required to be operable, unless efforts have failed to re-establish feedvater using the HFPs, the steam turbine driven AFPs and the HDFP. Surveillance Requirement 4.7.1.2.a.4, instead of License condition 2.C.(3)(t), vill require isolation of the SUFP suction, discharge and cooling vater lines while the AFPs are

4 1 4 . !' . .

Dockot No. 50-346' l .

. Licens2 No. NPF-3 Serial No. 1439 '

Attachment 1 Page 7 required to be operable (Modes 1, 2 and 3), thereby eliminating the concerns for non-scismic/high energy and moderate energy pipe failures in the AFP rooms. The proposed changes to the AFW System Technical Specification, regarding the applicability of Specification 4.0.4 to the AFV SRs, simply clarify what exists currently in the AFV Syctem Technical Specifiestion (10CFR50.59(a)(2)(ii)).

- Not reduce the margin of safety as defined in the basis for any Technical Specification because there vill be no change in the present method of plant operation in Modes 1, 2 and 3. The SUFP vill not be placed in service in Modes 1, 2 and 3, when the AFPs are required to be operable, unless efforts have failed to re-establish feedvater using the MFPs, the steam turbine driven AFPs and the HDFP. Surveillance Requirement 4.7.1.2.a.4, instead of License Condition 2.C.(3)(t), vill require isolation of the SUFP suction, discharge and ecoling vater lines while the AFPs are required to be operable (Modes 1, 2 and 3), thereby eliminating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms. The proposed changes to the AFV System Technical Specification, regarding the applicability of Specification 4.0.4 to the AFV SRs, simply clarify what exists currently in the AFV System Technical Specification (10CFR50.59(a)(2)(iii)).

CONCLUSION Lased on the above, it is concluded that the proposed Technical Specification and License Condition changes do not constitute an unreviewed safety question.

REFERENCE DOCUMENTS i

Technical Specification 3/4.7.1.2, Auxiliary Feedvater System l Technical Specification Basis 3/4.7.1.2, Auxiliary Feedvater Systems Updated Safety Analysir Report (USAR) Sections 3.6.2.7.2.12 and 7.4.1.2.5 .

I l

l l

i

Doc'ker No. 50-346 -

a Liesnso No. $PF-3 Scrial No. 1489 g 7 l License Condition 2.C.(3)(t)

Ace,ordingly, 7Jding paragraphFacility (Operating 2.C. 3)(t) to read Lir.ense No. NPF-3 is hereby amended by as follows: ..

Toledo Cdison shall operate the Startup Feedwater Pump (SUFP) System with the following operational restrictions:

1. Toledo Edison will station an operator in the Startup Feedwater Pump / Auxiliary Feedwater Pump (SUFP/AFW) area during operation of the SUFP to nonitor SUFP/ Turbine Plant Cooling Water (TPCW) piping status in the AFW Pump Rooms. In the event of SUFP/TPCW pipe leakage, the operator will trip the SUFP locally or notify the Control Room to trip the SUFP, and isolate the SUFP/TPCW piping.

2.

Toledo Edison will isoitte and maintain isolation outside the SUFP/AFW area of the SUFP suction, discharge, and turbine plant cooling water piping, when the SUFP is not in operation (Modes 1, 2 and 3).

3. Toledo Edison will install a SUFP, associated piping, and valves, to remove the hazards to the AFW pumps before commencing Cycle 6 i

L i

l Date of Issuance: January 8, 1935 1

i I

$US STARTUP FEEDWATER PUMP CONFIGURATION 222 ra :s a w en n

.?2o .?

Ei& Y

'?W wm TURt31NE PLANT COOLING WATER SYSTEP[ SUPPLY FEEDWATER [ FEEDWATER l TURBINE PLANT COOLING WATER SYSTEM RETURN HEATER HEATER )l 1

-t-3 (( 3 J CONDENSATE CONDENSATE STORAGE STORAGE TANK TANK O l-I -2 CWl97 j y

1f X

TV -

Cwl96

• TO AFP S 1

~

.TND MDFP l V FW91 TO* TO #2

_ m2  %

Jk MFP MFP >

FW 906 w2  %

Cc% :7 , g FW32 9

S T A RT-U P "

i FEED PUMP C i

i

DockOt No. 50-346

. LicGnse No. NPF-3 Serial No. 1489 Attachment 2 Page 1 SIGNIFICANT HAZARDS CONSIDERATION DESCRIPTION OF THE PROPOSED ACTIVITY The purpose of this License Ammendment Request is to review proposed changes to the Davis-Besse Nuclear Power Station Unit No. 1 Operatin'j License, Appendix A Technical Specif.ications. The proposed changes 4nvolve replacing the Startup Feedvater Pump (SUFP) License Condition 2.C.(?>(t) with a Surveillance Requirement and associated Basis change, an/. clarifying when the provisions of Specification 4.0.4 are not applicable for the Auxiliary Feedvater (AFV) Surveillance Requirements.

In January 1985, License Condition 2.C.(3)(t) vas imposed on the SUFP after it was determined that non-seismic /high energy and moderate energy SUFP/ Turbine Plant Cooling Vater (TPCV) piping failures could potentially jeopardize operation of the Auxiliary Feedvater Pumps (AFP). License Condition 2.C.(3)(t) (Attachment I of the Safety Evaluation) imposed operational restriction.= on the SUFP. These restrictions included: 1) stationing an operator in the SUFP/AFP area during SUFP operation; 2) isolating the SUFP and TPCV piping outside the SUFP/AFP area; and 3) instr.lling a new SUFP pr19r to Cycle 6 operation.

In 1986, electrical power to the SUFP motor was removed and the SUFP vas functionally replaced with a Motor Driven Feedvater Pump (HDFP). The HPFP was installed outside of the AFP rooms to be used during plant startups and shutdowns and as an additional source of feedvater in the event the Main Fecdvater Pumps (HFP) and the steam turbine driven AFPs failed.

During the fifth refueling outage, the SUPP vill be repovered to provide an additional means to remove decay heat via the steam generators. It vill be locally operated and vill not be used in Modes 1, 2 and 3, when the AFPs are required to be operable, unless other efforts have failed tn re-establish feedvater using the HFPs, steam turbine driven AFPs and the HDFP. The SUFP/TPCV lines, which isolate the SUFP outside of the AFP rooms, vill be valved closed in Hodes 1, 2 and 3, thereby removing the potential hazard to the AFPs by SUFP operation. Plant procedures vill provide operator instructions for placing the SUFP in service in the unlikely event that both HFPs, both AFPs and the HDFP fail. Since the SUFP vill not be used (unless the above conditions are encountered) in Modes 1, 2, and 3 (when the AFPs are required to be operable), the concern for SUFP and TPCV pipe failures in the AFP rooms vill be eliminated.

This request proroses deleting License Condition 2.C.(3)(t) and incorporating Item 2 of License Condition 2.C.(3)(t) as Technical Specification Surveillance Requirement 4.7.1.2.a.4. The AFV System Basis is also being revised to reflect this change. Additionally. Toledo Edison pr.3 poses clarifying when the provisions of Specification 4.0.4 are not applicable for the AFV Surveillance Requirements.

i '

Dockst N3. 50-346 LicGnsa No. NPF-3 Serial No. 1489 Attachment 2 Page 2 DOCUMENTS AFFECTED ST 5071.14, Auxiliary Feedvater Train 1 Monthly Valve Verification ST 5071.24, Auxiliary Feedvater Train 2 Honthly Valve Verification SP 1106.27, Startup Feedvater Pump Operating Procedure EP 1202.01, RPS, SFAS, SFRCS or SG Tube Rupture Emergency Procedure AD 1838.00, Surveillance and Periodic Test Program SYSTEMS AND COMP 0NENTS AFFECTED Hain Feedvater (HFV) System Auxiliary Feedvater (AFV) System Motor Driven Feedvater Pump (HDFP) System Startup Feedvater Pump (SUFP) System SAFETY FUNCTIONS OF SYSTEMS AFFECiED The HFV System supplies the normal source of feedvater to the steam generators. It provides the steam generators with enough vater to replace the steam leaving the units.

The safety function of AFU System is to supply feedvater to the steam generators for the removal of reactor decay heat in the absence of HFV and/or to promote natural circulation of the Reactor Coolant System in the event all four reactor coolant pumps fail.

The function of the HDFP System during routine plant operation is to provide feedvater to the steam generators during startups and shutdovns. The HDFP also serves the functicn of providing a diverse means of supplying AFV to the steam generators as a backup to the steam turbine driven AFPs. The HDFP may be aligned to the HFV System at or belov 40% power and is aligned to the AFV System above 40% power.

The SUFP vill serve no safety function. It ves used as part of the original plant design, during startup and shutdown when '.: sufficient steam vaa available to drive the HFPs. However, operation was limited by Licence Condition 2.C.(3)(t) after it was determined that piping failures could l jeopardize the AFPs. In the new configuration, the SUFP vill not be used in Modes 1, 2 or 3, when the AFPs are required to be operab'a, unless other )

efforts have failed to re-establish feedvater using *i.e HFPs, the steam turbine driven AFPs and the HDFP. Surveillance Requirement 4.7.1.2.a.4 vill .

require isolation of the SUFP suction, discharge and cooling vater lines, thereby eliminating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms when the AFPs are required to be operable. Since the AFPs are not required to be operable in Modes 4, 5 and 6, the SUFP may be used in Modes 4, 5 and 6.

EFFECTS ON SAFETY 1

License Condition 2.C.(3)(t) vas added in January 1985 by License Amendment No. 83 (Log No. 1672). Since that time, Toledo Edison has installed the HDFP to provide an additional, redundant source of feedvater. The HDFP is located outside of the AFP rooms, thereby removing the hazards to the AFPs. The HDFP

a Y -

Dockot No. 50-346

, Licsnsa No. NPF-3 Serial No. 1489 Attachment 2 Page 3 is used during normal plant operation for startup and shutdown. Toledo Edison is repovering the SUFP to provide an additional means to remove decay heat via the steam generators. The SUFP is not to be used in Modes 1, 2 or 3, unless other efforts have failed to re-establish feedvater using the NFPs, the steam turbine driven AFPs and the MDFP. Since the proposed Surveillance Requirement slll prevent SUFP operation in Modes 1, 2 or 3, the concerns for non-sidsmic/high energy and moderate energy pipe failures in the AFP rooms vill be eliminated when the AFPs are required to be operable.

Each item of License Condition 2.C.(3)(t) is discussed below.

Item 1 of License Condition 2.C.(3)(t) requires Toledo Edison to station an operator in the SUFP/AFP area during operation of the SUFP to monitor the SUFP/TPCV piping in the AFP rooms. In the event of a SUFP/TPCW pipe leakage, the operator vill trip the SUFP locally or notify the Control Room to trip the SUFP and isolate the SUFP/TPCV piping.

The SUFP vill not be used in Modes 1, 2 or 3, when the AFPs are required to be operable, unless other efforts have failed to re-establish feedvater using the MFPs, the steam turbine driven AFPs and the MDFP. Surveillance Requirement 4.7.1.2.a.4 vill require isolation of the SUFP suction, discharge and cooling vater lines, thereby eliminating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms when the AFPs are required to be operable. Thus, there is no longer a concern to have an operator stationed in the SUFP/AFP area to isolate the SUFP/TPCV piping to eliminate an AFP room flooding hazard. Since the AFPs are not required to be operable in Modes 4, 5 and 6 the SUFP may be used in Modes 4, 5 and 6. Also, because the SUFP vill 3

not be used when the AFPs are required to be operable, i.e., in Modes 1, 2 and 3, the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms vill be eliminated. Toledo Edison therefore proposes

deleting Item 1 of License Condition 2.C.(3)(t).

1 Item 2 of License Condition 2.C.(3)(t) requires Toledo Edison to isolate and d

maintain isolation outside the SUFP/AFP area of the SUFP suction, discharge and TPCV piping when the SUFP is not in operation (Modes 1, 2 and 3).

l In conjunction with returning electrical power to the SUFP motor, Toledo Edison proposes to isolate and maintain isolation of the SUFP/AFP area.

l Isolation vill be verified through an additional Technical Specification '

Surveillance Requirement. Surveillance Requirement 4.7.1.2.a.4 vill be added l

, to the AFV System Technical Specification and vill require verifying, on a 31-day staggered test basis, for each AFV train, that the TPCV valves (CVl96 anC CVl97), the SUFP suction valves (FV32 and FV91) and the SUFP discharge valve (FV106) are closed (see Attachment II of the Safety Evaluation). By

, maintaining these valves closed, the SUFP/TPCV lines located in the AFP rooms vill be isolated, thereby negating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP rooms when the AFPs are required  !

to be cperable. Toledo Edison also proposes to add to the Basis the j explanation thet by verifying these valves are closed, concerns associated l with pipe failures in the AFF rooms are addressed. Toledo Edison therefore j proposes deleting Item 2 of License Condition 2.C.(3)(t) and incorporating i Technical Specification Surveillance Requirement 4.7.1.2.a.4 in the AFV System  !

Technical Specification, i

i

I

• Dock 3t No.'50-346 Lic;nso No. NPF-3 I Serial No. 1489 Attachment 2 Page 4 Item 3 of License Condition 2.C.(3)(t) requires that Toledo Edison install a SUFP, associated piping and valves to remove the hazards to the AFPs prior to commencing Cycle 6.

Consistent with the intent of Item 3 of License Condition 2.C.(3)(t), Toledo Edison has installed the HDFP. The HDFP is located outside of the AFP rooms, thereby removing the hazards to the AFPs. Toledo Edison is repovering the SUFP as an additional source of feedvater. However, since the SUFP vill not be used in Modes 1, 2 or 3 when the AFPs are required to be operable, the hazards to the AFPs vill be eliminated. Therefore, Toledo Edison proposes deleting Item 3 of License Condition 2.C.(3)(t).

Toledo Edison also proposes clarifying when the provisions of Specification 4.0.4 are not applicable for the AFV Surveillance Requirements (SR). The currently written exception is confusing.

An exception to Specification 4.0.4 is necessary for two of the AFV SRs.

Because the AFV System Technical Specification is applicable in Modes 1, 2 and 3, the AFV SRs are required to be performed at the frequencies specified to verify system operability. The SRs are also performed when coming up in pover, prior to entering Mode 3 from Mode 4, if they have not been performed within the frequencies specified. Per;ormance of two of the AFV SRs however requires the plant to be in Mode 3. SR 4.7.1.2.a.1 requires verifying that each steam turbine driven pump develops a differential pressure of greater than or equal to 1070 psid on recirculation flov vben the secondary steam supply pressure is greater than 800 psia, i.e. the plant to be in Mode 3.

Similarly, SR 4.7.1.2.b.2. requires verifying that each pump starts automatically upon receipt of an AFV actuation test signal which requires the plant to be in Mode 3 to prof 9 a steam generator supply which is adequate to conduct the test, i.e., main steam pressure of greater than or equal to 800 psia. Therefore, these two SRs should be clarified to allov entry into Mode j 3, to perform the surveillance, since they cannot be performed in Mode 4, i.e., prior to entering Mode 3, as the Applicability Statement dictates. This can be accomplished by providing an exception to Specification 4.0.4 for entry into Mode 3 for SR 4.7.1.2.a.1 and 4.7.1.2.b.2.

l The currei.tly written exception is confusing in that Mode 3 of the I Applicability Statement and SR 4.7.1.2.b.2 refer to a footnote at the bottom i of the page that says the provision of section 3.0.4 is not applicable for  !

entry into Mode 3. Specification 3.0.4 states "Entry into an OPERATIONAL MODE l or other specified applicability condition shall not be made unless the conditions of the Limiting condition for Operation are met vithout reliance on provisions contained in the ACTION statements unless otherwise excepted. This provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION statements" and applies to Limiting Conditions for Operation. As discussed la Basis section 3.0.4, exceptions to Specificatior 3.0.4 are stated in the ACTION statements of the appropriate specifications.

Specif4. cation 4.0.4 states: "Entry into an OPERATIONAL H0DE or other specified applicability condition shall not be made unless the Surveillance Requirement (s) associated with the Limiting Condition for Operation have been performed within the stated surveillance interval or as othervise specified" and applies to Surveillance Requirements (SR). An exemption to Specification 4.0.4 vould permit completion of SRs 4.7.1.2.a.1 and 4.7.1.2.b.2 as it vould

e

~ '

f I Dockot No. 50-346

. Lic:nsa No. NPF-3 Serial No. 1489 Attachment 2 Page 5 permit entry into Mode 3 from Mode 4 to perform the surveillance test. ,

Because Specification 3.0.4 applies to Limiting Conditions for Operation and Specification 4.0.4 applies to SRs, Specification 4.0.4 is the appropriate reference for the AFV SRs.

Therefore, this application proposes clarifying that the provisions of Specification 4.0.4 are not applicable, for entry into Mode 3, for SRs 4.7.1.2.a.1 and 4.7.1.2.b.2, as the SRs require the plant to be in Mode 3 to produce a steam generator steam supply which is adequate to conduct the surveillances. The remaining AFV SRs can be performed prior to entering Mode 3, which is required by the Applicability Statement, therefore, no additional clarifications regarding Specification 4.0.4 are necessary.

SIGNIFICANT HAZARDS CONSIDERATION The Commission has provided standards in 10CFR50.92(c) for determining whether a significant hazard exists. A proposed amendment to an Operating license for ,

a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment vould not: 1) involve a significant increase in the probability or consequences of an accident previously evaluated; 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in the margin of safety. The Company 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 vould Not involve a significant increase in the probability or consequences of an accident previously evaluated in the USAR because there vill be no change in the present method of plant operation in Modes 1, 2 and 3. The SUFP vill not be placed in service in Modes 1, 2 and 3, when the AFPs are required to be operable, unless efforts have failed to re-establish feedvater using the MFPs, the steam turbine driven AFPs and the MDFP. Surveillance Requirement 4.7.1.2.a.4, instead of License Condition 2.C.(3)(t), vill require isolation  ;

of the SUFP suction, discharge and cooling vater lines while the AFPs are required to be operable (Modes 1, 2 and 3), thereby eliminating the concerns i for non-seismic /high energy and moderate energy pipe failures in the AFP I rooms. The proposed changes to the AFV System Technical Specification, regarding the applicability of Specification 4.0.4 to the AFV SRs, simply clarify what exists currently in the AFV System Technical Specification (10CFR50.92(c)(1)).

Not create the possibility of a new of different kind of accident from any accident previously in the USAR because there vill be no change in the present I metho6 of plant operation in Modes 1, 2 and 3. The SUFP vill not be placed in l service in Modes 1, 2 and 3, when the AFPs are required to be operable, unless .

efforts have failed to re-establish feedvater using the MFPs, the steam  !

turbine driven AFPs and the MDFP. Surveillance Requirement 4.7.1.2.a.4, I instead of License Condition 2 C.(3)(t), vill require isolation of the SUFP suction, discharge and cooling vater lines while the AFPs are required to be  ;

operable (Modes 1, 2 and 3), thereby eliminating the concerns for i non-seismic /high energy and moderate energy pipe failures in the AFP rooms. I l

l

'? I Docket No. 50-346

, License No. NPF-3 Serial No. 1489 Attachment 2 Page 6

The proposed changes to the AFV System Technical Specification, regarding the applicability of Specification 4.0.4 to the AFV SRs, simply clarify what exists currently in the AFV System Technical Specification

, (10CFR50.92(c)(2)).

Not involve a significsit reduction in a margin of safety because there vill be no change in the present method of plant operation in Modes 1, 2 and 3.

! The SUFP vill not be p'. aced in service in Modes 1, 2 and 3, when the AFPs are required to be operab',e, unless ef forts have failed to re-establish feedvater using the MFPs, the rteam turbine driven AFPs and the MDFP. Surveillance Requirement 4.7.1.2.a.4, instead of License Condition 2.C.(3)(t), vill require isolation of the SUFP suction, discharge and cooling vater lines while the AFPs are required to be operable (Modes 1, 2 and 3), thereby eliminating the concerns for non-seismic /high energy and moderate energy pipe failures in the AFP tooms. The proposed changes to the AFV System Technical Specification, i regarding the applicability of Specification 4.0.4 to the AFV SRs, simply clarify what exists currently in the AFV System Technical Specification (10CFR50.92(c)(2)).

CONCLUSION on the basis of the above, Toledo Edison has determined that the amendment request does not involve a significant hazards consideration.

REFERENCE DOCUMENTS Technical Specification 3/4.7.1.2, Auxiliary Feedvater System Technical Specification Basis 3/4.7.1.2, Auxiliary Feedvater Systems

Updated Safety Analysis Report (USAR) Sections 3.6.2.7.2.12 and 7.4.1.2.5 1

4 1

i l

4

! i n

I j

i

_. . _ _ . _ _ . _ _ _ _ , _ . _ _ . . _ , _ _ _ . _ _ - - . _ . . _ . . , - . . _ . - . . _ _ _ - . . _ ~ _ . _ , . , .- _