ML20207K107

Safety Evaluation Supporting Amend 120 to License NPF-3

ML20207K107
Person / Time
Site:	Davis Besse
Issue date:	09/19/1988
From:	Office of Nuclear Reactor Regulation
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Shared Package
ML20207K100	List: ML20207K096 ML20207K107
References
NUDOCS 8809280242
Download: ML20207K107 (3)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 120 TO FACILITY OPERATING LICENSE NO. NPF-3 TOLEDO EDISON COMPANY AND THE CLEVELAND ELECTRIC ILLUM,INATING COMPANY DAVIS-BESSE nut' LEAR POWER STATION, UNIT NO 1 DOCKET NO. 50-346

1.0 INTRODUCTION

By letter dated December 8,1987 Toledo Edison Company proposed a.'evision to the Dtvis-Besse Nuclear Power Station, Unit No.1. Technical Specifications (TS's). The proposed change would make Surveillance Requirement 4.6.1.2 c.3 consistent with the wording of 10 CFR Part 50, Appendix J. and ANSI N45.4-1972.

Toledo Edison Company asserts that the surveillance requirement, as presently worded, is contrary to the provisions cf ANSI N45.4-1972, Appendix C, and is

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not consistent with the NRC position r lating to the rate of gas injection or bleed-off from containment during testing. Toledo Edison Company fu;'ther asserts that with the present wording of the TS'S, if the initial Type A test leakege were zero, a valid supplemental test could not be performed to the requirements of 10 CFR Part 50, Appendix J and ANSI N45.4-1972.

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2.0 DISCUSSION Every license issued under 10 CFR Par *, 50 is deemed to have certain conditions as part of the license whether specifically stated in the license on not (cf.

10 CFR 50.54). One of these conditions imposes the requirements of Appendix J to 10 CFR Part 50 relating to primary containment leakage testing. Appendix J provides for pre-operational and periodic verification of leak-tight integrity of the primary reactor contair, ment.

Appendix J defines three types of tests to be conducted. This proposed amendment relates to the Type A tests, which are defined as tests intended to measure the primary containment overall integrated leakage rate (1) after the containment has been completed and is ready for operation, and (2) at periodic i

intervals thereafter.

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. Paragraph III. A.3.(b) of Appendix J specifies that the accuracy of type A tests shall be verified by a supplemental test, and an acceptable rethod for such tests is described in ANSI N45.4-1972, Appendix C.

Supplemental test results are acceptable if the difference between the supplemental test data leakage rate at the calculated peak pfes(or L ) (Lsure for the Design Basis Acciden and Type A test data is within 0.25 L is the maximum allowable t

(DBA),andL is the maximum allowable leakage rate at the reduced test t

pressure. )

The ANSI N45.4-1972 method involves the use of an adjustable orifice (microadjustable instrument flow control valve). The valve and suitable flow meter are installed at a convenient containment penetration.

In use, the leak orifice is adjusted to provide a flow during the test approximating (at test pressure conditions) the leakage rate specified for the containment vessel. The leak orifice 1:, to be selected to provide a flow of 75 to 125 percent of L,.

Surveillance Requirement 4.6.1.2 c.3 of the TS presently specifies that the quantity of gas injected into or bled from the containment system during the supplemental test is to be enutvalent to at least 25 percent of the total measured leahge rate at the calculated peak pressure for the DBA, P,, (38 psig).

3.0 EVALVATION Toledo Edison Company has proposed to revise this paragraph to specify that the rate at which gas is injected into or bled from containment during the supplemental test is to La between 0.75 and 1.25 of L This changewouldthenmaketheTSrequirementconsistentwiththere$u.irements of ANSI /ANS 56.8-1981 ANSI N45.4-1972, and Appendix J to 10 CFR Part 50.

The change also would allow conducting a supplemental test even if the medsured Containment leakage were zero, whereas under the present TS requirement, a valid supplemental test cannot be performed since no gas would be injected into or bled from containment.

The staff has reviewed the proposed change to TS paragraph 4.6.1.2 c.3 and finds the change acceptable on the basis that it eliminates an inconsistency between the station TS's and the Comission's regulations; furthermore, the change eliminates the potential for not being able to perfctm a valid test if the measured leakage is zero.

The staff also notes that Inspection Report No. 50-346/84-29(DRS),issuedby the NRC on February 8,1988, identified the discrepancy between the station TS's and Appendix J to 10 CFR Part 50 as an open item. This change should resolve that open item.

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4.0 ENVIRONMENTAL CONSIDERATION

This amendment involves changes in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and a change to a surveillance requirement. The staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves r.o significant hazards consideration, and there has been no public comment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of thi amendmeat.

5.0 CONCLUSION

The staff has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Albert W. De Agazio Dated: September 19. 1988 i

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