ML20212C879

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Safety Evaluation Supporting Amend 96 to License NPF-3
ML20212C879
Person / Time
Site: Davis Besse 
Issue date: 12/22/1986
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20212C842 List:
References
TAC-55782, NUDOCS 8612310220
Download: ML20212C879 (3)


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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR RFACTOR REGULATION SUPPORTING AMENDMENT NO. 96 TO FACILITY OPERATING LICENSE N0. NPF-3 TOLED0 EDISON COMPANY AND THE CLEVELAND ELECTRIC ILLUMINATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346 INTRODUCTION By letter dated August 27, 1984 (No. 1074) Item 2, the Toledo Edison Company proposed changes to Appendix A Technical Specification (TS) Section 4.7.1.2.

The proposed changes related to the requirements identified in our Safety Evaluation Report (SER) dated February 21, 1984, which addressed the TMI Action Plan NUREG-0737, Item II.E.1.1.

That SER stated that Toledo Edison Company must propose Technical Specifications to satisfy Recommendations GS-2, GS-6, and additional Short-term Recommendation 4.

The required changes relate to the following surveillance requirements:

Verification that all local manual valves in the Auxiliary Feedwater (AFW) system that affect system function are locked in the proper positions, Verification of the normal AFW flow path from primary water source to the steam generators prior to plant startup following an extended cold shutdown or following any modification or repair that could affect normal AFW flow, The stationing of an individual at local manual valves which must be repositioned when conducting surveillance tests on the AFW system.

On May 9, 1985, the NRC issued its evaluation of Toledo Edison Company's August 27, 1984 proposed TS changos. The May 9, 1985, SER concluded that the proposed changes were deficient in certain areas and, therefore, were not acceptable.

Specifically, with respect to the requirement to verify the normal flow path following extended cold shutdown, repair, or modification, the use of flow indication was not acceptable to the NRC staff, and the proposed surveillance requirement did not specify that the verification was from the primary water source to the steam generators. Additionally, the requirement to verify flow path after modification or repair did not allow for the fact that repair could be performed in Modes 1 or 2 and, therefore, a stipulation in the proposed change that the verification would be required prior to entering Mode 3 is not applicable.

Thus, the NRC staff concluded that the requirement of GS-6 was not met. Other changes proposed did, however, conform to the requirements of GS-2 and Short-term Recommendation 4, but pending revision of the application to satisfy all tha criteria, none were incorporated into the license.

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. '0ISCUSSION AND EVALUATION On August 29, 1985 (No. 1180), the licensee submitted a revised application for amendment to remedy the deficiencies identified in the staff's May 9,1985 SER and to clarify certain existing surveillance requirements. The licensee's application proposed changes to TS Sections 3.7.1.2 and 4.7.1.2.

The proposed TS changes modify paragraph 4.7.1.2.a.2 and add paragraph 4.7.1.2.a.3.

These paragraphs now would require verification each 31 days l

(on a staggered basis) that for each AFW system all power operated and automatic valves in the flow path are in the correct position and that all t

manual valves in the AFW suction and discharge path that affect the system's capacity to deliver water to the steam generator are locked in their proper position. These proposed verifications comply with the guidelines of GS-2 and are, therefore, acceptable.

The proposed TS changes clarify the requirements of paragraphs 4.7.1.2.b.1 and 4.7.1.2.b.2. -Paragraph 4.7.1.2.b.1 requires periodic verification that each automatic valve in the flow path actuates to the correct position on an AFW actuation test signal. The requirement has been clarified to indicate that the verification is to be done prior to entering Mode 3.

Since the Applicability of the Limiting Condition for Operation for the AFW system is Modes 1, 2 or 3, this clarification is acceptable.

Paragraph 4.7.1.2.b.2 requires verification that each pump starts automatically upon receipt of an AFW actuation test signal. The licensee proposes to add the clarification that this test will be conducted prior to entering Mode 2.

The licensee states that this verification requires the plant to be in Mode 3 to produce a steam generator steam supply which is adequate to conduct the test, i.e.,

main steam pressure 3,800 psia. The licensee notes that steam from the auxiliary boiler cannot be automatically initiated by the steam and feedwater rupture control system. The staff finds this clarification acceptable.

Associated with the change proposed for paragraph 4.7.1.2.b.2, the licensee proposes a note to indicate that the provision of TS Section 3.0.4 is not applicable for entry into Mode 3 from Pode 4.

This note is necessary to i

allow the verification required by paragraph 4.7.1.2.b.2.

The inclusion of the notation is acceptable to tne staff.

The proposed TS changes would add paragraphs 4.7.1.2.b.3, 4.7.1.2.e and 4.7.1.2.f.. Paragraph 4.7.1.2.b.3 concerns verifying the flow path from the 4

condensate storage tank to the steam generator by observing either a level change in the steam generator or by observing flow on the safety-grade flow indicator. This change complies with the criteria of GS-6 and is, therefore, acceptable.

Paragraph 4.7.1.2.e concerns verifying the flow path after any modification or repair that could affect the system capability to deliver water to the steam generator.

If the repair or modification is made downsteam of the test flow line, the AFW system would be tested to verify flow from the i -

condensate storage tank to the steam generator.

Verification would be either by a change in steam generator water level or safety-grade flow indication.

If the repair or modification is upstream of the test flow line, the system would be tested to verify flow through the test flow line j

using flow indication in the test line.

The staff had indicated in its 4

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May 9,1985 SER that the use of AFW flow indication to verify delivery of water to the steam generator was not acceptable. However, with the additional specification that safety-grade instrumentation would be used if verification is through the use of flow indication instead of water level change, the staff finds that paragraph 4.7.1.2.e is acceptable.

Paragraph 4.7.1.2.f concerns verifying the flow path after each cold shutdown more than 30 days in Mode 5.

This requirement is identical to the requirement of paragraph 4.7.1.2.b.3.

The staff finds that this verification of a flow path from the condensate storage tank to the steam generator using either steam generator level change or safety-grade flow indication meets the guidelines of GS-6 and is, therefore, acceptable.

The licensee has proposed a note to TS 4.7.1.? which specifies when conducting tests of the AFW system in Modes 1, 2 and 3 which require realignment of local manual valves that make the system inoperable, a dedicated individual will be stationed at the valves and in comunication with the control room in order to be able to restore the system to operable status, if necessary. This proposed change to the TS complies with Additional Short-term Recommendation 4 and is, therefore, acceptable.

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 changes in surveillance requirements. We have 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 no 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 1mpact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

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CONCLUSION l

We have concluded, based on the considerations discussed above, that:

l (1) there is reasonable assurance that the health and safety of the public

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will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations i

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.

Dated:

December 22, 1986 Principal Contributors:

A. De Agazio L. Kelly i

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