ML20217P867
| ML20217P867 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/24/1998 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC |
| Shared Package | |
| ML20217P851 | List: |
| References | |
| NUDOCS 9805070114 | |
| Download: ML20217P867 (11) | |
Text
Docket Number 50-346 License Number NPF-3 Serial Number 2519 i
. Enclosure l Page 2 l 1
APPLICATION FOR AMENDMENT TO 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.
The proposed changes (submitted under cover letter Serial Number 2519) concern:
Appendix A, Technical Specifications (TS):
TS 3/4.3.1.1 Reactor Protection System Instrumentation TS 3/4.3.2.1 Safety Features Actuation System Instrumentation TS 3/4.3.2.2 Steam and Feedwater Rupture Control System Instrumentation TS Bases 3/4.3.1 Reactor Protection System and Safety System and 3/4.3.2 Instrumentation i
By: .
{
J. K.[ood, Vice President - Nuclear j Sworn to and subscribed before me this 24th day of April,1998.
I
" b w _A Notary Public, Stand of Ohio Nora Lynn Flood My Commission expires September 4, 2002, 9905070114 990424 i DR ADOCK 050003 6 l J
Docket Number 50-346 License Number NPF-3 Serial Number 2519
. Attachment l
l SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST 97-0004 (25 pages follow) l I
LAR 97-0004 Page1 SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 97-0004 TITLE:
Relocate Response Time Limit Tables from Technical Specification (TS) 3/4.3.1.1, Reactor Protection System Instrumentation, TS 3/4.3.2.1, Safety Features Actuation System Instrumentation, and TS 3/4.3.2.2, Steam and Feedwater Rupture Control System Instrumentation, to the Updated Safety Analysis Report.
DESCRIPTION:
The purpose of this License Amendment Request is to change Davis-Besse Nuclear Power Station (DBNPS) Operating License NPF-3, Appendix A, Technical Specifications (TS) 3/4.3.1.1, Reactor Protection System (RPS) Instrumentation, TS 3/4.3.2.1, Safety Features Actuation System (SFAS) Instrumentation, and TS 3/4.3.2.2, Steam and Feedwater Rupture Control System (SFRCS), by relocating the tables of response time limits for these systems from the TS to the DBNPS Updated Safety Analysis Repon's (US AR) Technical Requirements Manual (TRM). In addition, related chariges are proposed for TS Bases 3/4.3.1 and 3/4.3.2, Reactor Protection System and Safety System Instrumentation. The TRM is a DBNPS - controlled document that has been incorporated into the USAR.
These proposed changes are based on the Nuclear Regulatory Commission's (NRC) line-item TS improvement in Generic Letter (GL) 93-08, " Relocation of Technical Specification Tables of Instrument Response Time Limits", dated December 29,1993. {
Although GL 93-08 addresses only the RPS and SFAS response time tables, the DBNPS t is also proposing relocation of the SFRCS response time table because this table content I is similar in scope to the RPS and SFAS tables. The proposed removal of these three l response time tables from the Tb, including the SFRCS response time limits, is consistent I with NUREG-1430, Revision 1, " Improved Sta.ndard Technical Specifications for Babcock and Wilcox Plants," dated April 7,1995.
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j The present TS Limiting Conditions for Operation (LCOs) for tl e RPS, SFAS and SFRCS instrumentation require that these systems be operable with response time limits )
as specified in TS tables for each of these systems. The present TS Surveillance Requirements specify that the DBNPS test these systems and verify that the response time of each function is within its limits. Relocating the tables of RPS, SFAS and SFRCS I instrumentation response time limits from the TS to the USAR will not alter the basic i
content of the Surveillance Requirements for testing the response times, which would be retained within the TS. The USAR TRM would provide the response time limits for this i
LAR 97-0004 Page 2
' instrumentation, including identifying those channels for which the response time is indicated as "NA", i.e., a response time limit is not applicable.
Footnotes currently modify each of the TS response time limit tables. Per the guidance of GL 93-08,in order to retain the effect of these footnotes following the relocation of the tables to the USAR, the TS Surveillance Requirements are proposed to be changed to incorporate these footnotes.
The following changes are proposed under this License Amendment Request:
TS 3/4.3.1.1, RPS Instrumentation: Relocate Table 3.3-2, RPS Instrumentation Response Times, to the USAR TRM. Modify LCO 3.3.1.1 to eliminate the reference to Table 3.3- >
- 2. Modify Surveillance Requirement 4.3.1.1.3 to incorporate the existing Table 3.3-2 I footnotes which: exempt neutron detectors from response time testing, describe the means of performing response time testing when not including the neutron detectors, describe what the response times include, and describe that the Reactor Coolant Pump (RCP) monitor has an assumed delay time. Consistent with the purpose of GL 93-08 to relocate numerical response times to the USAR, the numerical value of the delay time assumed for the RCP monitor in the determination of the response time of the High Flux / Number of RCPs On functional unit is being relocated to the USAR TRM as a footnote to the relocated RPS instmmentation response times.
TS 3/4.3.2.1, SFAS Instrumentation: Relocate Table 3.3-5, Safety Features System Response Times, to the USAR TRM. Modify LCO 3.3.2.1 to eliminate the reference to Table 3.3-5 Modify Surveillance Requirement 4.3.2.1.3 to incorporate the existing Table 3.3-5 footnotes which: describe the inclusion of applicable emergency diesel generator start and sequence loading delays into the determination of the response time limits, and describe the inclusion of the movement of valves and the attainment of pump or blower discharge pressure into the determination of the response time limits.
TS 3/4.3.2.2, SFRCS Instrumentation: Relocate Table 3.3 13, SFRCS Response Times, to the USAR TRM. Modify LCO 3.3.2.2 to eliminate the reference to Table 3.3-13.
Modify Surveillance Requirement 4.3.2.2.3 to incorporate the existing Table 3.3-13 footnotes which describe how the Main Steam Isolation Valve and Turbine Stop Valve response times are determined.
TS Bases 3/4.3.1 and 3/4.3.2, Reactor Protection System and Safety System Instrumentation: Add the sentence: 1 The response time limits for these instrumentation systems are located in the Updated Safety Analysis Report and are used to demonstrate OPERABILITY in accordance with each system's response time surveillance requirements.
LAR 97-0004 Page 3
' This sentence explains that operability of the RPS, SFAS, and SFRCS is based, in part, on measured response times being cc isistent with those in the tables relocated to the USAR TRM.
Delete the sentence:
No credit was taken in the analyses for those channels with response times indicated as not applicable.
since the table showing the response times as not applicable will be removed from the TS.
This sentence will be relocated to the USAR TRM Bases.
The TRM is part of the USAR and it is therefore requ: red that any revisions to it be evaluated under the regulatory requirements of Section 50.59," Changes, Tests and Experiments," of Title 10 of the Code of Federal Regulations (10 CFR).
The proposed TS changes will allow the DBNPS to control and evaluate future revisions to the RPS, SFAS and SFRCS tables of response time limits in accordance with 10 CFR 50.59 without the need for the DBNPS and the NRC to process a License Amendment Request when such changes are not an unreviewed safety question or do not involve a change to a TS.
SYSTEMS, COMPONENTS. AND ACTIVITIES AFFECTED:
This proposed license amendment affects the administrative location of the tables of TS response time limits for the RPS, SFAS and SFRCS instrumentation, associated footnotes and an associated TS Bases change.
FUNCTIONS OF THE AFFECTED SYSTEMS COMPONENTS, AND ACTIVITIES:
The overall function of the Operating License, Appendix A, TS,is to impose those conditions or limitations upon reactor operation necessary to preserve the validity of the results of USAR Design Bases Accident analyses. The function of the tables of response time limits in TS 3/4.3.1.1, RPS Instrumentation, TS 3/4.3.2.1, SFAS Instrumentation, and TS 3/4.3.2.2, SFRCS Instrumentation, is to provide assurance that the RPS, SFAS and SFRCS actuation functions associated with each channel are completed within the time limit assumed in the DBNPS safety analyses. These tables provide the acceptance criteria for the response time tests performed to satisfy the Surveillance Requirements of TS 3/4.3.1.1. TS 3/4.3.2.1 and TS 3/4.3.2.2 for each applicable RPS, SFAS and SFRCS actuation function.
5 The RPS, SFAS and SFRCS instrumentation systems are protection systems and are described in DBNPS USAR Section 7.0," Instrumentation and Control." The USAR
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' states the purpose of the RPS is to initiate a reactor trip when a sensed parameter F group of parameters) exceeds a setpoint value indicating the approach of an unsafe condition, protecting the reactor core from exceeding design limits and the Reactor Coolant System (RCS) from overpressurization. The RPS response time is defined in TS Definition 1.25 as the time interval from when the monitored parameter exceeds its trip setpoint at the channel sensor until power interruption at the control rod drive breakers.
The USAR states the purpose of the SFAS is to automatically prevent or limit fission product and energy release from the core by isolating the containment vessel and initiating operation of the Engineered Safety Features (ESF) System equipment during a Loss-Of-Coolant Accident (LOCA), and to also mitigate the consequences of a LOCA.
The safety features response time is defined in TS Definition 1.26 as the time interval from when the monitored parameter exceeds its SFAS actuation setpoint at the channel sensor until the safety features equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). This time includes the emergency diesel generator starting and sequence loading delays, where applicable.
The purpose of the SFRCS as described in the USAR is to mitigate the release of high energy steam, to automatically start the Auxiliary Feedwater System in the event of a main steam line or main feedwater line rupture, to automatically start the Auxiliary Feedwater System on the loss of both main feed pumps or the loss of all four RC pumps, and to
' prevent steam generator overfill and subsequent spillover into the main steam lines. The SFRCS also provides a trip signal to the Anticipatory Reactor Trip System (ARTS). The SFRCS response time is defined in TS Definition 1.28 as the time interval from when the monitored parameter exceeds its SFRCS actuation setpoint at the channel sensor until the equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.).
EFFECTS ON SAFETY:
The Limiting Conditions for Operation (LCOs) for RPS, SFAS and SFRCS instrumentation currently require that these systems be operable in accordance with the response times specified in the TS tables for each of these systems. The Surveillance Requirements specify that each of these systems be periodically tested and that the response time of each function be verified to be within its limits. The periodic measurements of response times provide assurance that a reactor trip, SFAS actuation, and an SFRCS actuation associated with specific channels is completed within the time assumed in the USAR.
The proposed changes to TS 3/4.3.1.1, TS 3/4.3.2.1, and TS 3/4.3.2.2 and their associated Bases will relocate the tables of response time limits in the TS to the USAR TRM.
However, the Surveillance Requirements for performing the response time testing will be m . . .
. LAR 97-0004 Page 5
' retained within the RPS, SFAS and SFRCS TS. The removal of the specific response time limits tables from the TS does not eliminate the TS requirements for the DBNPS to ensure this instrumentation is capable of performing their safety functions. Requirements related to the operability, applicability, and Surveillance Requirements, including
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performance of testing to ensure response times for the RPS, SFAS, and SFRCS are met, '
are retalin with the TS due to those systems' importance in mitigating the consequences of an accident.
These proposed changes are based on the recommendations in the NRC's Generic Letter 93-08, " Relocation of Technical Specification Tables of Instrument Response Time Limits," dated December 29,1993, where the NRC concluded that response time tables for various instrument channels and components are not required to be retained within the TS. Generic Letter 93-08 addressed specifically only the RPS and SFAS response time '
tables, however, the DBNPS is also proposing that the SFRCS response time tables be relocated because this table is similar in scope to the RPS and SFAS tables.
10 CFR Section 50.36 establishes the regulatory requirements for licensees to include TS as part of applications for operating licenses. In addition, the Nuclear Regulatory Commission's " Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," dated July 22,1993, provides guidance regarding the required content of TS. The fundamental purpose of the TS, as described in the NRC's Final Policy Statement, is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety. This is accomplished by identifying those features that are of controlling importance to nuclear safety and establishing on them certain TS conditions of operation which cannot be changed without prior NRC approval.
The NRC's Final Policy Statement recognized, as had previous statements related to the NRC Staff's TS Improvement Program, that implementation of the policy would result in the relocation of some existing TS requirements to licensee-controlled documents such as the USAR. Those items relocated to the USAR would, in turn, be controlled in accordance with the requirements of 10 CFR Section 50.59.10 CFR Section 50.59 provides criteria to determine when facility or operating changes planned by a licensee require prior NRC approval in the form of a license amendment in order to address any unreviewed safety questions or TS changes.
The proposed changes and relocations are consistent with the NRC's determination, on a generic basis, that response time limits for protection systems such as the RPS, SFAS and SFRCS need not be specified within the TS. This determination was provided by NRC Generic Letter 93-08 and approved in the NRC's staff Safety Evaluations for Amendment Number 93 (NRC TAC Number M93347) to Operating License Number NPF-42 for the Wolf Creek Generating Station, dated December 12,1995 and for Amendment Numbers 202 and 187 (NRC TAC Numbers M92496 and M92497) to Operating Licenses Numbers
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' DPR-58 and DPR-74 for the Donald C. Cook Plant Units 1 and 2, dated October 10, 1995. The NRC staff conchtded that the response time limits are considered to be an l operational detail related to licensees' safety analyses and can be adequately controlled by the requirements of 10 CFR 50.59. Therefore, the continued processing oflicense amendments related to revisions of the affected instrument or component response times, where the revisions to those requirements do not involve an unreviewed safety question under 10 CFR 50.59, would afford no significant benefit with regards to protecting the public health and safety. Further, the administrative location of the response time requirements do not constitute a condition or limitation on operation necessary to obviate the possibility'of an abnormal situation or event giving rise to an immediate threat to the public health and safety, in that the ability of the RPS, SFAS and SFRCS to perform their safety functions is not adversely impacted by the relocation of the response time limit tables from the TS to the USAR TRM.
Under the proposed changes, the tables of response time limits contained in TS 3/4.3.1.1, TS 3/4.3.2.1, and TS 3/4.3.2.2 and their associated TS Bases will be relocated to the USAR TRM. The numerical value of the delay time assumed for the RCP monitor in the determination of the response time of the High Flux / Number of RCPs On functional unit will also be relocated as a footnote to the relocated RPS response time limits table.
Following NRC staff approval of this proposed amendment, these tables will be added to the USAR TRM concurrently with their removal from the TS. This action will be accomplished within the amendment implementation period allowed by the NRC staff. l Future changes to these response times tables in the USAR TRM will be evaluated, prior to implementation, in accordance with the regulatory requirements of 10 CFR Section 50.59. Therefore, these administrative changes will have no adverse effect on nuclear safety.
The proposed changes to incorporate the response time table footnotes into the TS Surveillance Requirements is necessary in order to retain their effect on modifying their associated TS response time limit table. These footnotes will also be included with the tables relocated to the USAR TRM. The relocation of the specified delay time from the RPS response time footnote assumed for the Reactor Coolant Pump monitor is consistent w3h the overall administrative relocation of response times to the USAR TRM. These are alministrative changes which have no adverse effect on nuclear safety.
The propo2d change to remove the sentence in TS Bases 3/4.3.1 and 3/4.3.2 which refers to response time limits in the TS table indicating "not applicable", is consistent with the removal of the table from TS. This sentence will be relocated to the USAR TRM Bases. !
This is an administrative change which has no adverse effect on nuclear safety.
1 In summary, the proposed relocation of the response time limit tables of TS 3/4.3.1.1, 3/4.3.2.1 and 3/4.3.2.2 and their associated TS Base.s relocation to the USAR TRM will not affect the RPS, SFAS and SFRCS response times from being within their limits, alter the performance of the associated Surveillance Requirements, or adversely affect the
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' systems' operation and ability to perform their safety-related functions. These TS changes are administrative and consistent with guidance from the NRC. Any future changes to ,
these relocated requirements will be evaluated as required by 10 CFR 50.59. Therefore, there is no adverse effect on nuclear safety as a result of these changes and relocation.
SIGNIFICANT HAZARDS CONSIDERATION:
l The Nuclear Regulatory Commission has provided standards in 10 CFR Section 50.92(c) l for determining w hether a significant hazard exists due to a proposed amendment to an i 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:
l (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 Power Station (DBNPS) has reviewed the
, proposed changes and determined that a significant hazards consideration does not exist l because operation of the Davis-Besse Nuclear Power Station, Unit Number 1, in I accordance with these changes would:
la. Not involve a significant increase in the probability of an accident previously l evaluated because no accident initiator, conditions or assumptions are affected by the proposed changes to Technical Specification (TS) 3/4.3.1.1, Reactor Protection System (RPS) Instrumentation, TS 3/4.3.2.1, Safety Features Actuation System (SFAS) Instrumentation, and TS 3/4.3.2.2, Steam and Feedwater Rupture Control System (SFRCS) Instrumentation and the associated TS Bases to relocate their tables of response time limits to the Technical Requirements Manual (TRM) of the DBNPS Updated Safety Analysis Report (USAR).
The RPS, SFAS and SFRCS response time limits and surveillance intervals currently prescribed in the TS are not changed under the proposed License Amendment. The RPS, SFAS and SFRCS will continue to function in the manner described in the DBNPS USAR.' Therefore, the performance of these protection systems will remain within the bounds of the USAR accident analysis.
Under the proposed changes, the response time limits of the RPS, SFAS and SFRCS would continue to be tested in accordance with plant procedures in the same manner as in the past. The specific RPS, SFAS and SFRCS tables of response time limits will be relocated and remain controlled by the TRM of the l DBNPS USAR following the guidance of the NRC's Generic Letter (GL) 93-08, l
" Relocation of Technical Specification Tables of Instrument Response Time Limits," dated December 29,1993. Any change to the relocated tables for
, response time limits will be subject to review and evaluation under Section 50.59, !
l " Changes, Tests, and Experiments," of Title 10 of the Code of Federal Regulation (10 CFR) prior to any changes being made.
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LAR 97-0004 Page 8 Ib. Not involve a significant increase in the consequences of an accident previously evaluated because no accident conditions or assumptions are affected by the proposed changes. As described above, the changes are consistent with the guidance of NRC GL 93-08. The proposed changes administratively relocate response time tables and do not alter the source term, containment isolation, or allowable releases. The proposed changes, therefore, will not increase the radiological consequences of a previously evaluated accident.
- 2. Not create the possibility of a new or different kind of accident from any accident previously evaluated because no new accident initiators or assumption's are -
introduced by the proposed changes, which involve only the administrative '
relocation of response time limit tables. No new accident scenarios, transient
. precursors, failure mechanisms, or limiting failures are introduced as a result of the proposed changes. As described above, the changes are consistent with the guidance of NRC GL 93-08. The proposed changes do not alter any accident scenarios and future changes to the response time limits will be subject to the regulatory requirements in 10 CFR 50.59.
- 3. Not involve a significant reduction in a margin of safety because the proposed changes only administratively relocate the response time tables from the TS to the USAR TRM, and do not reduce or adversely affect the capabilities of any plant structures, systems or components. No response times will be changed by this amendment request. Future changes to the response time limits will be subject to the regulatory requirements of 10 CFR 50.59. Accordingly, there is not a reduction in a margin of safety.
CONCLUSION:
On the basis of the above, the Davis-Besse Nuclear Power Station has determmed that the License Amendment Request does not involve a significant hazards consideration.
Furthermore, as this License Amendment Request concerns a proposed change to the Technical Specifications that must be reviewed by the Nuclear Regulatory Commission, i 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. DBNPS Technical Specifications 3/4.3.1.1, Reactor Protection System Instrumentation, 3/4.3.2.1, Safety Features Actuation System Instrumentation, and 3/4.3.2.2, Steam and
LAR 97-0004 Page 9 Feedwater Rupture Control System Instrumentation and their associated TS Bases, 3/4.3.1 and 3/4.3.2 (through Operating License Amendment No. 219).
- 2. The NRC's " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," (58 FR 39132, dated July 22,1993).
- 3. " Improved Standard Technical Specifications for Babcock and Wilcox Plants,"
NUREG-1430, Revision 1, dated April 7,1995.
I
- 4. " Relocation of Technical Specification Tables ofInstrument Response Time Limits,"
NRC Generic Letter 93-08, dated December 29,1993. (Toledo Edison Log No. 4134).
l S. NRC Steff Safety Evaluation for Amendment Number 93 (NRC TAC Number M93347) to Operating License Number NPF-42 for the Wolf Creek Generating Station, approved December 12,1995.
- 7. 10 CFR 50.36," Technical Specifications." l
- 8. 10 CFR 50.59, " Changes, Tests, and Experiments."
l
- 9. NRC Staff Safety Evaluation for Amendment Numbers 202 and 187 (NRC TAC Numbers M92496 and M92497) to Operating License Number DPR-58 and DPR-74 i for the Donald C. Cook Nuclear Plants, Unit Number 1 and 2, approved October 10, l 1995. I
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