ML20195F912
| ML20195F912 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/10/1999 |
| From: | Campbell G CENTERIOR ENERGY |
| To: | |
| Shared Package | |
| ML20195F909 | List: |
| References | |
| NUDOCS 9906150135 | |
| Download: ML20195F912 (13) | |
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Docke' Number 50-346 i
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' License Number NPF-3 L
Serial Number 2500 Enclosure
.Page1 1
APPLICATION FOR AMENDMENT TO i
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.
1 The proposed changes (Submitted under cover letter Serial Number 2500) concern:
1 Appendix A, Technical Specifications:
' Page XVI Index 3/4.6.4.4
. Hydrogen Purge System (and Bases) 3/4.6.5.1 Shield Building Emergency Ventilation System (and Bases) 3/4.7.6.1 Control Room Emergency Ventilation System (and Bases) 6.0 Administrative Controls
. I, Guy G. Campbell, state that (1) I am Vice President - Nuclear of the FirstEnergy Nuclear Operating Company, (2) I am duly authorized to execute and file this certification on behalf of the Toledo Edison Company and The Cleveland Electric Illuminating Company, and (3) the statements set forth herein are true and correct to the best of my knowledge, information and belief.
By:
Guy G. Cargpbell, Vice PrMent - Nu ear u
Affirmed and subscribed before me this 10th Day of June, 1999.
I duits)
- Notary Public, State of Ohio LAuaA A. ANNISON Notary PuWic, State of Ohle Mr Conwnission Empires 615 2001 l
9906150135'990610.
3 PDR ADOCK 05000346 8 P-PDR 1 g
Dockst Number 50-346 License Number NPF-3 Serial Number 2500 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, Facility Operating License Number NPF-3, Appendix A, Technical Specifications. The changes involve Technical Specification (TS) 3/4.6.4.4 - Hydrogen Purge System (and Bases), TS 3/4.6.5.1 - Shield Building Emergency Ventilation System (and Bases), TS 3/4.7.6.1 - Control Room Emergency Ventilation System (and Bases), and TS 6.0 - Administrative Controls.
' A. Time Required to Implement: These changes will be implemented within 120
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' days after the NRC issuance of the License Amendment.
B. Reason for Change (License Amendment Request 96-0013):
This application proposes adoption of a Ventilation Filter Testing Program f
(VFTP)in TS Section 6.0 - Administrative Controls and removal of the detailed l
ventilation filter testing requirements from the DBNPS Surveillance Requirements of TS 3/4.6.4.4 - Hydrogen Purge System, TS 3/4.6.5.1 - Shield Building Emergency Ventilation System, and TS 3/4.7.6.1 - Control Room Emergency Ventilation System. The detailed filter testing requirements of these TS will be replaced with a reference to the Ventilation Filter Testing Program requirements being added as TS Section 6.8.4.f-Ventilation Filter Testing Program. These changes will consolidate the various TS ventilation filter testing requirements under a single program consistent with the improved Standard Technical Specifications of NUREG-1430, Revision 1.
C. Safety Assessment and Significant Hazards Consideration: See Attachment.
1 i
Dock:t Number 50-346 License Number NPF-3 J
Serial Number 2500 Attachment i
SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION
'FOR LICENSE AMENDMENT REQUEST NO. 96-0013 (26 pages follow) l i
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LAR 96-0013 Page1 SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 96-0013 TITLE:
Proposed Revision of Technical Specification (TS) 3/4.6.4.4 - Hydrogen Purge System, TS 3/4.6.5.1 - Shield Building Emergency Ventilation System, TS 3/4.7.6.1 -
Control Room Emergency Ventilation System and TS 6.0 - Administrative Controls.
DESCRIPTION:
The purpose of this license amendment request is to add a Ventilation Filter Testing Program (VFTP) requirement in TS Section 6.0 - Administrative Controls and remove the detailed ventilation filter testing requirements from the DBNPS i
Surveillance Requirements (SRs) of TS 3/4.6.4.4 - Hydrogen Purge System, TS 3/4.6.5.1 - Shield Building Emergency Ventilation System, and TS 3/4.7.6.1, Control Room Emergency Ventilation System. The detailed filter testing requirements of these SRs will be replaced with a reference to the Ventilation Filter Testing Program requirement being added in TS Section 6.8.4.f-Ventilation Filter Testing Program.
Replacing these SRs with a Ventilation Filter Testing Program (VFTP) TS requirement will consolidate the detailed SRs of three TS into a single program requirement for managing ventilation filter surveillances and tests. This is consistent with the NRC's NUREG-1430, Revision 1, Standard Technical Specifications - Babcock and Wilcox Plants.
The relocation of SR test frequencies to the VFTP will also allow for future adjustment of test frequencies. Any proposed adjustment will be subject to the 10CFR50.59 process or engineering evaluation process, as applicable, to ensure the proposed adjustment is acceptable. For example, a literal reading of SR 4.7.6.1.c requires ventilation filter testing (including a flow test) following any touch up painting, no matter how small, in a Control Room ventilation zone communicating with the Control Room Emergency Ventilation System. Following relocation of this requirement to the VFTP, an evaluation may be prepared under the 10CFR50.59 process that revises the requirement to allow for a limited amount of painting to be performed that has been evaluated as having no detrimental effect on the ventilation filters.
The following identifies the destination for these SRs being, in essence, relocated to TS 6.8.4.f:
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Hydrogen Purse System Existing New TS 6.8.4.f SR
' Subject Subpart 4.6.4.4.b.1 In place penetration and bypass leakage 1 and 2 testing of the atmosphere cleanup system (HEPA and charcoal adsorber banks) 4.6.4.4.b.2, Laboratory analysis of a representative carbon 3
4.6.4.4.c sample 4 6.4.4.d.1 Pressure drop across combined HEPA filters 4
and adsorber banks 4.6.4.4.d.2 Heater dissipation of energy 5
4.6.4.4.e HEPA filter post-replacement test 1
4.6.4.4.f Charcoal adsorber bank post-replacement 2
test Shield Building Emergency Ventilation System Existing New TS 6.8.4.f SR Subject Subpart 4.6.5.1.b.1:
In place penetration and bypass leakage 1 and 2 testing of the atmosphere cleanup system (HEPA and charcoal adsorber banks) 4.6.5.1.b.2 Laboratory analysis of a representative 3
4.6.5.1.c carbon sample j
4.6.5.1.b.3 System flow rate 1 and 2 4.6.5.1.d.1 Pressure drop across combined HEPA filters 4
and adsorber banks i
4.6.5.1.e HEPA filter post-replacement test 1
4.6.5.1.f Charcoal adsorber bank post-replacement 2
test Control Room Emergency Ventilation System Existing New TS 6.8.4.f SR Subject Subpart 4.7.6.1.c.1 In place penetration and bypass leakage 1 and 2 testing of the atmosphere cleanup system (HEPA and charcoal adsorber banks) h
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IAR 96-0013 Page 3 J
l 4.7.6.1.c.2 -
Laboratory Analysis of a representative 3
4.7.6.1.d carbon sample 1
4.7.6.1.c.3 System flow rate 1 and 2 4.7.6.1.e.1 Pressure drop across combined HEPA filters 4
and adsorber banks 4.7.6.1.f HEPA filter post-replacement test 1
i 4.7.6.1.g Charcoal adsorber bank post-replacement test 2
i The following is the VFTP description that would be added as Section 6.8.4.f, Ventilation Filter Testing Program (VFTP):
A program shall be established to implement the following required testing of j
safety related filter ventilation systems at the frequencies specified in the VFTP
. and in accordance with Regulatory Guide 1.52, Revision 2, ANSI /ASME N510-1980,-and ASTM D 3803-1979 under the conditions noted in the program.
1.
Demonstrate for each of the safety related systems that an in-place test of the high efficiency particulate air (HEPA) filters show a penetration and system bypass <1% when tested in accordance with Regulatory Guide 1.52, Revision 2 and ANSI /ASME N510-1980 at the system flowrate specified 1
below, +/- 10%.
Safety Related Ventilation System Flowrate i
i Containment Hydrogen Purge System 100 cfm i
Shield Building Emergency Ventilation System 8000cfm Control Room Emergency Ventilation System 3300cfm i
2.
Demonstrate for each of the safety related systems that an in-place test of the charcoal adsorber shows a penetration and system bypass < 1% when i
l tested in accordance with Regulatory Guide 1.52, Revision 2 and ANSI /
l ASME N510-1980 at the system flowrate specified below, +/- 10%.
l Safety Related Ventilation System Flowrate Containment Hydrogen Purge System 100cfm Shield Euilding Emergency Ventilation System 8000 cfm Control Room Emergency Ventilation System 3300 cfm i
~ LAR 96-0013 1
Page 4 i
3.
Demonstrate for each of the safety related systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than the value specified below when tested in accordance with ASTM D 3803-1979 at a temperature of 30 C and greater than or equal to the relative humidity specified below, with the following conditions:
- 1) equilibrate for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />
- 2) challenge for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />
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- 3) clution for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Safety Related Ventilation System Penetration RH Containment Hydrogen Purge System 1%
70%
Shield Building Emergency Ventilation System 1%
70%
Control Room Emergency Ventilation System 1%
70%
4.
Demonstrate for each of the safety related systems that the pressure drop across the ecmbined HEPA filters, the prefilters*, and the charcoal adsorbers is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2 and ANSI /ASME N510-1980 at the system flowrate specified below, +/-10%.
Safety Related Ventilation System Delta P Flowrate Containment Hydrogen Purge System 25 Inches Water Gauge 100 cfm Shield Building Emergency Ventilation System 6 Inches Water Gauge 8000 cfm Control Room Emergency Ventilation System 4.4 Inches Water Gauge 3300 cfm
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- Containment Hydrogen Purge does not contain prefilters, 5.
Demonstrate that the heaters for the safety related Containment Hydrogen Purge System dissipate 2000 watts +/- 20% when tested in accordance with ANSI /ASME N510-1980.
The provisions of SR 4.0.2 and SR 4.0.3 are applicable to the VFTP test frequencies.
The Bases to TS 3/4.6.4.4, TS 3/4.6.5.1, and TS 3/4.7.6.1 would be revised to reflect the above changes using the NUREG-1430, Revision 1 Bases as a guideline. Page XVI of the TS Index would also be revised to reflect a pagination change due to the above changes.
, Page 5 SYSTEMS. COMPONENTS. AND ACTIVITIES AFFECTED:
The systems, components and activities'affected by this proposed license amendment concern the content and administrative location of the detailed surveillance testing requirements for the ventilation filters for the Hydrogen Purge System, the Shield Building Emergency Ventilation System and the Control Room
. Emergency Ventilation System.
FUNCTIONS OF THE AFFECTED SYSTEMS. COMPONENTS. AND ACTIVITIES:
Hydrogen Purre System The Hydrogen Purge System is a safety-related system described in the DBNPS Updated Safety Analysis Report (USAR) Section 6.2.5.2.2, " Hydrogen Purge System." The Hydrogen Purge System is designed to release air nom the Containment Vessel through High Efficiency Particulate Air (HEPA) and charcoal
- filters to the DBNPS's stack vent. The Hydrogen Purge System functions to relieve the pressure that would be built up inside containment from the operation of the Containment Hydrogen Dilution blowers after a Design Basis Accident. The
- Hydrogen Dilution Blowers would pressurize the containment with fresh air in order to dilute the hydrogen that is being produced from various sources inside containment. The Hydrogen Dilution Blowers would continue to function alone to dilute hydrogen until the containment pressure limit of eighteen psig is reached.
The Hydrogen Purge System would then be used to prevent any additional pressure
- increase by venting the containment atmosphere through the HEPA and charcoal filters to the station stack vent.
Shield Buildina Emergency Ventilation System The Shield Building Emergency Ventilation System (EVS) is described in USAR Section 6.2.3," Containment Vessel Air Purification and Cleanup Systems." The function of the EVS is to collect and process potential leakage from the Containment Vessel to minimize environmental activity levels resulting from all
, sources of containment leakage following a loss-of-coolant-accident (LOCA).
The EVS is designed to provide a negative pressure within the annular space between the Shield Building and the Containment Vessel and in the penetration rooms contiguous to containment following a LOCA and to reduce airborne fission product leakage to the environment by filtration prior to release of air through the station stack vent, j
LAR 96-0013 Page 6 The system has two redundant, independent subsystems, each fully capable of the functional requirement. A single failure of an active component in either subsystem does not affect the functional capability of the other subsystems. Each of the two redundant subsystems is capable of maintaining the annulus at a measurable minimum negative pressure of 1/4 inch water gauge.
Each of the two redundant subsystems is provided with prefilters, HEPA filters and charcoal adsorbers to remove airborne particles and methyl iodide as well as elemental iodine contaminants resulting from a LOCA. These units have a total efficiency not less than 95 percent.
Control Room Emergency Ventilation System j
The Control Room Emergency Ventilation System (CREVS) is discussed in USAR Section 9.4.1, " Control Room." The CREVS consists of two full capacity, redundant, fan-filter assemblies and is Seismic Class I. Each filter system includes a roughing filter (prefilter), a HEPA filter and charcoal adsorber. The operation of the CREVS is required to mitigate the consequences of a Design Basis Accident.
During normal operation, the control room emergency ventilation system is held on standby. In the event of high radioactivity after a LOCA, the control room normal 1
air conditioning system is automatically shut down and the control room emergency ventilation system is manually activated. During emergency isolation of the control room, the normal supply and return fans are shut down automatically and all control room isolation dampers are closed to preclude the admission of airborne contaminants to the control room. The control room operator has manual controls for initiating the control room emergency ventilation system to ensure satisfactory
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control room conditions following an accident. The control room emergency ventilation system filters have a total efliciency not less than 95 percent so that the i
limits of Criterion 19 of10 CFR 50 Appendix A are met.
EFFECTS ON SAFETY:
The replacement of the ventilation filter testing TS SRs with a reference to the VFTP being added in TS Administrative Controls Section 6.8.4.f, Ventilation Filter Testing Program, follows the NRC guidance document NUREG 1430, Revision 1, Standard Technical Specifications - Babcock and Wilcox Plants, April 1995. This will consolidate the various detailed TS ventilation filter testing requirements under a single program requirement for managing ventilation filter surveillances and tests.
LAR 96-0013 Page 7 The safety functions of the Hydrogen Purge System, the EVS, and the CREVS are not affected by the replacement of the ventilation filter testing SRs with a reference to the VFTP description of TS 6.8.4.f. This proposed License Amendment does not change the way that the filters are tested. The ventilation filters will continue to be j
tested using the same methods as previously established in the individual SRs. The
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surveillance testing will continue to be conducted in accordance with the licensing j
basis and Regulatory Guide 1.52, Revision 2, ANSI /ASME N510-1980, and ASTM D i
3803-1979, as currently required by the individual SRs.
In order to preserve the plant-specific, current licensing basis of the DBNPS, it was necessary to propose some differences to the NUREG-1430, Revision I wording of TS 6.8.4.f. These are discussed below:
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- a. References to the filter ventilation systems as " Engineered Safety Feature" systems in NUREG-1430 have been replaced with references to j
" safety related" systems because the CREVS is not an Engineered Safety Feature at the DBNPS. All three systems are nuclear safety-related, i
however.
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- b. The NUREG-1430 wording states that the testing of the filter ventilation systems will be "at the frequencies specified in [ Regulatory Guide _.]."
j Thus, NUREG-1430 suggests in the bracketed portion that the test frequency be that specified in a Regulatory Guide, for example, Regulatory Guide 1.52, Revision 2. However, under Operating License j
Amendment Number 217, dated December 2,1997, the NRC approved, as discussed in its Safety Evaluation, a deviation from Regulatory Guide 1.52 regarding 18 month surveillance intervals for the EVS and the CREVS. Therefore, it is proposed that instead of referencing the
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Regulatory Guide, that the VFTP document itself be required to state the test frequencies.
The initial VFTP test frequencies will be based on those frequencies i
provided in Regulatory Guide 1.52, Revision 2 or the present TS SRs.
Future proposed changes to those test frequencies will be subject to I
evaluation under the 10CFR50.59 process or engineering evaluation process, as applicable. This will ensure that the proposed changes have no detrimental effect on the filter systems.
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- c. The present DBNPS TS contain certain conditions for performing tests in accordance with ASTM D 3803-1979 that appear as footnotes in each of the three TS. The VFTP will specify these conditions and, therefore, the
LAR 96-0013 Page 8 words "under conditions noted in the program" have been added to the reference to ASTM D 3803-1979 in proposed TS 6.8.4.f.
d - The present SRs for the EVS (4.6.5.1.d.1) and CREVS (4.7.6.1.e.1) do not include the prefilters for the pressure drop test. However, the VFTP TS 6.8.4.f does include the prefilters for these two systems when determining the pressure drop because these prefilters are in the airflow path. The Hydrogen Purge system does not have prefilters, so a footnote has been added to the VFTP TS providing this fact.
- e. The NUREG-1430 references to "SR 3.0.2" and "SR 3.0.3" at the end of the VFTP TS have been replaced with the comparable "SR 4.0.2" and "SR 4.0.3" for the DBNPS TS.
The proposed changes to the Bases of TS 3/4.6.4.4, TS 3/4.6.5.1 and TS 3/4.7.6.1 reflect the replacement of specific surveillance tests with the VFTP and are based upon the guidelines of NUREG-1430, Revision 1.
The surveillance testing will continue to be performed in accordance with the industry standards presently referenced in the SRs to ensure that the systems remain operable and capable of performing their intended function.
Replacement of the detailed TS SR testing with a reference to a VFTP as delineated in the newly created TS Section 6.8.4.f, Ventilation Filter Testing Program, will not impact the systems capabilities. The proposed TS changes will maintain similar operation, maintenance, testing and system operability controls for the systems.
Furthermore, because these three ventilation systems are nuclear safety-related and described in the USAR, future changes to their USAR-described operation or testing will be evaluated as required by the 10CFR50.59 safety review / evaluation process. Therefore, these TS changes will have no adverse effect on nuclear safety for the DBNPS.
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. The Davis-Besse Nuclear
LAR 96-0013 Page 9
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Power Station has reviewed the proposed changes and determined that a significant hazards consideration does not exist because operation of the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1, in accordance with this change would:
la. Not involve e significant increase in the probability of an accident previously evaluated because no change is being made to any accident initiator. The 4
replacement of the specific Technical Specification (TS) ventilation filter testing Surveillance Requirements for the Containment Hydrogen Purge System (3/4.6.4.4), Shield Building Emergency Ventilation System (3/4.6.5.1),
i and the Control Room Emergency Ventilation System (3/4.7.6.1), with a reference to the newly created Ventilation Filter Testing Program contained in
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TS Administrative Controls Section 6.8.4.f, Ventilation Filter Testing Program, is a removal and relocation of certain TS details. The proposed TS 6.8.4.f will, however, add controls to maintain similar operation, maintenance, testing and system operability for these three ventilation systems. The TS Bases changes reflect the use of the Ventilation Filter Testing Program. Therefore,it can be concluded that the proposed changes do not involve a significant increase in 1
the probability of an accident previously evaluated.
lb. Not involve a significant increase in the consequences of an accident previously evaluated because the proposed changes do not affect accident conditions or assumptions used in evaluating the radiological consequences of an accident.
No physical alterations of the DBNPS are involved, nor are plant operating methods being changed. The proposed changes do not alter the source term, containment isolation or allowable radiological releases.
2.
Not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed changes do not change the way the plant is operated. No new or different types of failures or accident initiators are being introduced by the proposed changes.
3.
Not involve a significant reduction in a margin of safety because no inputs into the calculation of any Technical Specification Safety Limit, Limiting Safety System Settings, Technical Specification Limiting Condition for Operation, or other previously defined margins for any structure, system, or component important to safety are being affected by the proposed changes.
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CONCLUSIONS:
.On the basis of the'above, the Davis-Besse Nuclear Power Station has determined i
that the License Amendment Request does not involve a significant hazards i
consideration. Furthermore, as this License Amendment Request concerns 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.
REFERENCES:
- 1. Davis-Besse Nuclear Power Station, Unit No.1, Operating License, Appendix A, Technical Specifications through Amendment 229
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- 2. Davis-Besse Nuclear Power Station, Unit No.1, Updated Safety Analysis Report, through Revision 21
- 3. NRC Regulatory Guide 1.52, Revision 2, dated March 1978; Design, Testing, and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants i
- 4. American National Standard ANSI /ASME N510-1980, Testing of Nuclear Air-1 Cleaning Systems
- 5. ' ASTM D 3803-1979, Standard Test Methods for Radioiodine Testing of Nuclear-Grade Gas Phase Adsorbents
- 6. NUREG-1430, Revision 1, Standard Technical Specifications - Babcock and Wilcox Plants, April 1995
- 7. 10 CFR 50.59, Changes, Tests and Experiments 4
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