ML20217R280

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Application for Amend to License NPF-3,clarifying LCO 3.6.1.3.a & Revising Surveillance Requirement 4.6.1.3.c
ML20217R280
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 08/26/1997
From: Jeffery Wood
CENTERIOR ENERGY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217R281 List:
References
NUDOCS 9709040386
Download: ML20217R280 (13)


Text

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CENTERION -

ENERGY 5501 N State Route 2 419-249-2300 John K. Wor)d can Hartx>r.OH 43449 FAX: 419 3218337 Vce Prescent . Nuclear Daws-Besse Docket Number 50-346 License Number NPF Serial Number 2433 August 26, 1997 United States Nedear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

License Amendment Application to Revise Technical Specification (TS) 3/4.6.1.3,-

Containment System - Containment Air Locks and associated TS Bases 3/4.6.1.3, Containment Air Locks, and TS Bases 3/4.9.4, Containment Penetrations (License Amendment Request No. 97-0014)

' Ladies and Gentlemen:

Enclosed is an application for an amendment to the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1 Operating License Number NPF-3, Appendix A, Technical Specifications. The proposed changes involve: Technical Specification (TS) 3/4.6.1.3, Containment Systems - Containment Air Locks, and associated TS Bases 3/4.6.1.3, o Containment Air Locks; and TS Bases 3/4.9.4, Containment Penetrations.

1 The proposed changes to TS .3/4.6.1.3 involve a clarification to Limiting Condition for Operation (LCO) 3.6.1.3.a and a revision to Surveillance Requirement (SR) 4.6.1.3.c.

7 The proposed change to LCO 3.6.1.3.a would revise the LCO to more clearly reflect the intent -

that both air lock doors be maintained closed except when the air lock is being used for entry

- and exit. This proposed change would preclude the need to enter the Action statement when only the outer air lock door is opened, not for the purpose of a containment entry, but rather to provide access for air lock maintenance or air lock surveillance testing.

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9709040386 970826 PDR- ADOCK 05000346

.P. PDR

Docket Number 50-346 License Number NPF-3 Serial Number 2433 Page 2 i

The prot >c.ed change to SR 4.6.1.3.c involves revisinc .he surveillance interval from "at least once per 6 months" to "at least once per REFUELING INTERVAL." A REFUELING INTERVAL is defined by TS Definition 1.42 as "a period of time 3; 730 days." This SR provides for periodic testing of the containment air lock interlock mechanisms, which ensure that only one door in each air lock can be opened at a time. This proposed change is in ac:ordance with Improved Standard Technical Specification Change Package Traveler No.

TSTF-17, Revision 1, which was approved by the NRC on March 13,1997.

Associated with the above proposed changes to TS 3/4.6.1.3, the associated Bases 3/4.6.1.3 would be revised to clarify when a containment air lock door may be opened and to describe the function of the air lock interlock mechanisms.

A change to TS Bases 3/4.9.4 is proposed to modify the guidelines relative to the routing of hoses and cables through the containment air lock during core alterations or during movement of irradiated fuel within the containment. This change is requestcd to increase flexibility in routing hoses and cabling to and from the containment during plant outages. This change is based on guidance from the NRC Safety Evaluation Report related to Amendment No.173 to Facility Operating License No. DPR-31 and Amendment No.167 to Facility Operating License No. DPR-41, Flerida Power and Light Company, Turkey Point Unit Nos. 3 and 4, Docket Nos. 50-250 and 50-251, dated May 11,1995.

Toledo Edison requests that this license amendment application be approved by March 2,1998.

Should you have any questions or require additiu.:al information, please contact Mr. James L. Freels, Manager - Regulatory Affairs, at (419) 321-8466.

Very truly yours, nzW MKIllaj Enclosure cc: A. B. Beach, Regional Administrator, NRC Region III A. G. Hansen, NRC/NRR Project Manager S. Stasek, NRC Region III, DB-1 Senior Resident Inspector J. R. Williams, Chief of Staff, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board

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  • *- Docket Number 50-346 License Number NPF Serial Number 2433

- Enclosure Page1-APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NUMBER NPF-3 DAVIS-BESSE NUCLEAR POWER STATION UNIT NUMBER 1 Attached are ti,e 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.

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The proposed changes (submitted under cover letter Serial Number 2433) concern:

. Appendix A, Technical Specifications (TS):

3/4.6.1.3 Containment Systems - Containment Air Locks Bases 3/4.6.1.3 Containment Air Locks Bases 3/4.9.4 Containment Penetrations-For: J. K. Wood, Vice President - Nuclear By: D

1. Las 4)lant' Manager Sworn to and subscribed before me this 26th day of August, 1997.

NC Oh Notary Public/ state of Ohio Nora Lynn Flood - My Commission expires 9/3/97.

Docket Number 50 346 License Number NPF-3 Serial Number M3 Enclosure Page 2

'Ihe following information is provided to support issume of the requested changes to the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1 Operating License Number NPF-3, Appendix A, Technical Specifications (TS), including changes to: TS 3/4.6.1.3, Containment Systems - Containment Air Locks, and associated Bases 3/4.6.1.3, Containment Air Locks; and TS Bases 3/4.9.4, Containment Penetrations:

A. Time Required to Implement: In order to have the changes paposed by this amendment application in effect during the Eleventh Refueling Outage, which is presently scheduled to commen e in April,1998, Toledo Edison requests that this amendment application be approved by the NRC by March 2,1998, with implementation to follow within 90 days thereafter.

B. Reason for Change (License Amendment Request Number 97-0014):

The proposed changes to TS 3/4.6.1.3 involve a clarification to Limiting Condition for Operation (LCO) 3.6.1.3.a and a revision to Surveillance Requirement (SR) 4.6.1.3.c.

The proposed change to LCO 3.6.1.3.a would revise the LCO to more clearly reflect the intent that both air lock doors be maintained closed except when the air lock is being ased for entry and exit. This proposed change would preclude the need to enter the Action statement when only the outer air lock door is opened, not for the purpose of a containment entry, but rather to provide access for air lock maintenance or air lock surveillance testing.

The proposed change to SR 4.6.1.3.c involves revising the surveillance interval from "at least once per 6 months" to "at least once per REFUELING INTERVAL." A

' REFUELING INTERVAL is defined by TS Definition 1.42 as "a period of time < 730 days." This SR provides for periodic testing of the containment air lock interlock-mechanisms, which ensure that only one door in each air lock can be opened at a time.

This proposed change is in accordance with Improved Standard Technical Specification Change Package Traveler No. TSTF-17, Revision 1, which was approved by the NRC on March 13,1997.

Associated with the above proposed changes to TS 3/4.6.1.3, the associated Bases-3/4.6.1.3 would be revised to clarify when a containment air lock door may be opened and to describe the function of the air lock interlock mechanisms.

A change to TS Bases 3/4.9.4 is proposed to modify the guidelines relative to the routing of hoses and cables through the containment air lock during core alterations or during s movement ofirradiated fuel within the ccntainment. This change is requested to increase flexibility in routing hoses and cabling to and from the containment during plant outages.

C. Safety Assessment and Significant rIazards Consideration: See Attachment.

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- Docket Number 50-346 -

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License Number NPF-3 SerialNumber 2433

- Attachment-SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR-

' LICENSE AMENDMENT REQUEST NUMBER 97-0014 (14 pages follow)

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SAFETY ASSESSMENT AND SIGNIFICANTIIAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 97-0014 TITLE:

License Amendment Application to Revise Technical Specification (TS) 3/4.6.1.3, Containment Systems'- Containment Air Locks and associated TS Bases 3/4.6.1.3, Containment Air Locks, and TS Bases 3/4.9.4, Containment Penetrations.

DESCRIPTION:

The purpose of the proposed changes is to modify the Davis-Besse Nuclear Power Station (DBNPS) Operating License NPF-3, Appendix A Technical Specifications (TS) and associated Bases.

The proposed changes to TS 3/4 6.1.3 involve a clarification to Limiting Condition for Operation (LCO) 3.6.1.3.a and a revision to Surveillance Requirement (SR) 4.6.1.3.c.

The proposed change to LCO 3.6.1.3.a would revise the LCO to more clearly reflect the intent

. that both air !ack doors be maintained closed except when the air lock is being used for entry

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and exit. This proposed change would preclude the need to enter the Action statement when only the outer air lock door is opened, not for the purpose of a containment entry, but rather to provide access for air lock maintenance or air lock surveillance testing.

The proposed change to SR 4.6.1.3.c involves revising the surveillance interval from "at least once per 6 months" to "at least once per REFUELING INTERVAL." A REFUELING INTERVAL is defined by TS Definition 1.42 as "a period of time < 730 days." This SR provides for periodic testing of the containment air lock interlock mechanisms, whic.h ensure that only one door in each air lock can be opened at a time. This proposed change is in accordance with Improved Standard Technice.1 Specification Change Package Traveler No.

TSTF 17, Revision 1, which was approved by the NRC on March 13,1997.

Associated with the above proposed changes to TS 3/4.6.1.3, the associated Bases 3/4.6.1.3 would be revised to clarify when a containment air lock door may be opened and to describe the function of the air lock interlock mechanisms.

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in addition, a change is proposed to TS Bases 3/4.9.4, Containment Penetrations, to modify the guidelines relative to the routing of hoses and cebles through the containment air lock during core alterations or during movement ofirradiated fuel within the containment. This change is requested to increase flexibility in routing hoses and cabling to and from the containment during plant outages. This change is based on guidance from the NRC Safety Evaluation Report related to Amendment No.173 to Facility Operating License No. DPR-31 and Amendment No.167 to Facility Operating License No. DPR-41, Florida Power and Light Company, Turkey Point Unit Nos. 3 and 4, Docket Nos. 50-250 and 50-251, dated May 11,1995.

The proposed changes are described in detail below. Each of the proposed changes is also shown on the attachment.

TS 3/4.6.1.3. Containment Systems - Containment Air Locks It is proposed to revise Limiting Condition for Operation (LCO) 3.6.1.3.a for clarification.

The new LCO 3.6.1.3.a would read as follows:

Each containment air lock shall be OPERABLE with:

a. Both doors closed except when the air lock is being used for entry ar,o exit, then at least one air lock door shall be closed, and It is also proposed to revise the surveillance interval for SR 4.6.1.3.c from "at least once per 6 months" to "at least once per IEFUELING INTERVAL." A REFUELING INTERVAL is defined by TS Definition 1.42 as "a period of time < 730 days " Accordingly, SR 4.6.1.3.c would read as follows:

Each containment air lock shall be demonstrated OPERABLE:

c. At least once per REFUELING INTERVAL by verifying that only one door in each air lock can be opened at a time.

Bases 3/4.6.1.3. Containment Air Locks Consistent wi:h the changes proposed to TS 3/4.6.1.3, the associated Bases is proposed to be expanded to clarify when a containment air lock door may be opened and to include a discussion of the function of the containment air lock interlock mechanisms. The following paragraph would be added:

The air lock interlock allows only one air lock door of an air lock to be opened at a time. This provision ensures that a gross breach of containment does not exist when CONT /ilNMENT IN7 EGPJTY is required. Closure of a single door in each air lock is sufficient to provide a leak tight barrier following postulated events. Nevertheless, in MODES 1 through 4, both doors are kept closed when the air lock is not being used

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.for entry and exit, i.e., containment entries / exits, air lock maintenance, or air lock testing.

Bases 3/4.9.4. Containment Penetrations This Bases is associated with TS LCO 3/4.9.4, Refueling Operations - Containment Penetrations, which is applicable during CORE ALTERATIONS or movement ofirradiated fuel within the containment. The current Bases includes the following statement:

A containment personnel air lock door is considered capable of being closed if the door is unblocked and there are no cables or hoses being run through the air lock.

It is proposed to revise this statement to add flexibility in routing cable aad hoses through the containment personnel air lock, provided that certain specified additional restrictions are met.

The revised statement would read:

A containment personnel air lock door is considered capable of being closed if the door is not blocked in such a way that it cannot be expeditiously closed, and any hoses and cables running through the air lock employ a means to allow safe, quick discormect or severance, and are tagged at the air lock with specific instructions to expedite removal.

SYSTEMS, COMPONENTS, AND ACTIVITIES AFFECTED:

The proposed changes involve the test frequency for the contain . at air lock interlock mechanism surveillance requirement. The proposed changes also involve the administrative controls governing the use of the containment personnel air lock during plant outages. There are no hardwam modifications involved.

FUNCTIONS OF TiiE AFFECI'ED SYSTEMS, COMPONENTS, AND ACTIVITIES:

The Containment Systems Technical Specifications Limiting Conditions for Operation (LCO) are based on requirements related to the control of offsite radiation doses resulting from major accidents. Compliance wi ht these LCOs, as demonstrated by performance of the associated surveillance testing, ensures a containment. configuration that will limit leakage to those paths -

and associated leakage rates assumed in the safety analysis.

/The containment system is described in the Davis-Beste Updated Safety Analysis Report (USAR) Sections 1.2 .10 - Contaimnent Systems,3.8.2.1 - Containment Vessel,3.8.2.2 -

Shield Building, and 6.2.1 - Contaimnent Vessel Functional Design. The containment is composed of a steel containment vessel and a reinforced concrete shield building. The containment vessel is a low-leakage cylindrical steel pressure vessel with a hemispherical dome and ellipsoidal bottom. The containment vessel, including its penetrations, is designed to withstand a postulated loss-of-coolant accident (LOCA) and to conf'me a postulated release a

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% ' LAR 97-0014 Page 4 of radioactive material. The shield building is a reinforced concrete structure having a cylindrical shape with a shallow dome roof. It completely surrounds the containment vessel and is designed to provide biological shielding during normal operation and from hypothetical accident conditions. An annular space is provided between the shield building and the

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containment vessel. The shield building provides a means of collection and filtration of fission product leakage from the containment vessel following a hypothetical accident. In addition, the shield building provides environmental protection for the containment vessel from adverse atmospheric conditions and external missiles.

Access to the containment is provided by an equipment hatch, a personnel air lock, and an emergency air lock. Electrical and mechanical penetrations are provided for services to the contair ment. Periodic leakage rate tests of the containment vessel and leak tests of the testable penetrations are conducted to verify their centinued leak-tight integrity.

The containment air locks are 10 CFR 50 Appendix J Type B penetrations. The containment personnel air lock is provided for routine transit into and out of contaimnent when CONTAINMENT INTEGRITY is required. The containment emergency air lock is provided for emergency access and exit. Each air lock has m e double-gasketed doors in series.

- Provision is made to pressurize the space between tne gaskets for testing purposes. In addition, the air locks have nozzles installed which permit pressure testing of the air lock at any time.

Each air lock door is designed such that with the other door in the same air lock open, the closed door can withstand and seal against the design pressure of the containment vessel.

During Modes 1 through 4, when one containment air lock door is open, the other door in the same air lock is required to be closed in accordance with TS LCO 3.6.1.3.a. This requirement, in conjunction with the containment air lock leakage limits, ensures that CONTAINMENT INTEGRITY is maintained during entry and exit through the containment air locks.

The air lock door interlock mechanism for each containment air lock ensures that only one of the two air lock doors within a containment air lock can be opened at a time, thereby ensuring CONTAINMENT INTEGRITY. The mechanical interlock devices ensure that one door cannot be opened until the second door is sealed. There is also visual indication outside each door showing whether the opposite door is open or closed. Provision is made outside each door for remotely closing and latching the opposite door so that in the event that one door is accidentally left open, it can be closed by remote control.

During CORE ALTERATIONS or movement ofirradiated fuel within the containment, in accordance with TS LCO 3.9.4.b, a minimum of one door in each air lock is required to be closed, but both doors of the containment personnel air lock may be open provided that at least one personnel air lock door is capable of being closed and a designated individual is available immediately outside the personnel air lock to close the door. These requirements ensure that, in the event a fuel handling accident occurs, the release of fission product radioactivity to the outside enviromnent will be minimized.

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k. LAR 7-0014 Page 5 EFFECTS ON SAFETY:

TS 3/4.6.1.3. Containtnent Systems - Containment Air Locks The proposed change to LCO 3.6.1.3.a clarifies the intent of the LCO. The present wording allows an exception applicable "for normal transit entry and exit through the containment."

The phrase "through the containment" could be interpreted to require entry into the TS Action statement when the outer air lock door (but not the inner door) is opened to provide access for air lock maintenance or surveillance testing. In addition, the phrase " normal transit" is subject to interpretation. The proposed change would remove the phra.ses " normal transit" and "through the containment." Associated with this change, the proposed revision to Bases 3/4.6.1.3, Containment Air Locks, includes clarification that "both doors are kept closed when the air lock is not being used for entry and exit, i.e., containment entries / exits, air lock maintenance, or air lock testing." The proposed changes are administrative changes which will have no adverse effect on plant safety.

The proposed change to SR 4.6.1.3.c, to revise the surveillance interval from "at least once per

. 6 months" to "at least once per REFUELING INTERVAL" is in accordance with Improved Standard Technical Specification Change Package Traveler No. TSTF-17, Revision 1, which was approved by the NRC on March 13,1997. The extended te%ig frequency isjustified due to the purely mechanical nature of the interlock mechanism, and given that the interlock mechanism is not normally challenged when the air lock door is used for entry and exit since administrative controls require strict adherence to single door opening. Further, the proposed change will allow perfomiance of the surveillance under the conditions that apply during a plant outage, which is preferable to performance, in part, with the, plant at power, as is currently necessitated by the present frequency. Performance of the surveillance with the piant at power, when containment integrity is required, carries with it the potential for loss of containment integrity, should the interlo::k fait during testing and allow both doors to be open simultaneously. In addition, the surveillance records and maintenance history records for the previous ten years were reviewed. This review demonstrates that the interlock mechanisms are very reliable. There were no surveillance test failures. In addition, the maintenance history records review did not reveal any equipment problems that would have rendered the interlock mechanism TS inoperabie. Based on this review and the additional facters cited above, the extended testing frequency isjustified and will have no adverse efTect on plant safety.

Bases 3/4.6.1.3. Containment Air Locks j

The proposed cimnges ta TS Bases 3/4.6.1.3 are administrative changes associated with the proposed changes to TS 3/4.6.1.3 and will have no adverse efTect on plant safety.

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k- LAR 97-0014 Page 6 Bases 3/4.9.4. Containment Penetrations The proposed change to TS Bases 3/4.9.4 to add flexibility in routing cable and hoses through the containment personnel air lock will not affect the present associated TS LCO 3.9.4.b requirement to maintain at least one containment personnel Mr lock door capable of being closed by a designated individual immediately outside the door. The proposed TS Bases will require that the door not be blocked in such a way that it cannot be expeditiously closed, and cny cables and hoses running through the air lock must employ a means to allow safe, quick disconnect or severance, and be tagged with specific instructions to expedite removal.

Section 15.4.7.3 of the USAR addresses a fuel handling accident inside containment. The analysis results are well within the 10 CFR 100 guideline values. Since the analysis does not take credit for containment isolation, the status of the personnel air lock has no impact on the acceptability of the results.

Under the proposed change, with both personnel air lock doors open, the requirements that at least one personnel air lock door be capable of being closed and that a designated individual be available immediately outside the personnel air lock to close the door will be unchanged. In

- the event of a fuel handling accident, closure of the door will minimize the release of radioactive material. Hence, this change will have no adverse effect on plant safety.

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 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, Unit No.1, in accordance with these changes would:

la. Not involve a significant increase in the probability of an accident previously evaluated because accident initiators, conditions, or assumptions are not affected by the proposed changes, which clarify the Technical Specification (TS) Limiting Condition for Operation (LCO) for the containme it air locks, extend the test frequency for the containment air lock interlock mechanisms, and modify guidelines relative to the routing of hoses and cables through the containment air lock during core alterations or during movement of irradiated fuel within the containment Ib. Not involve a significant increase in the consequences of an accident previously evaluated because the proposed changes do not change the source term, containment s

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isolation, or allowable releases. The proposed changes do not affect the allowable containment leakage rates presently specified in the Technical Specifications.

l The proposed change to Surveillance Requirement (SR) 4.6.1.3.c to increase the I

surveillance interval for the air lock interlock mechanism to "at least once per REFUELING INTERVAL" is justified due to the purely mechanical nature of the interlock mechanism, asd given that the interlock mechanism is not normally challenged when the air lock door is used for entry and exit since administrative controls require strict adherence to single door opening. Operating experience shows that the interlock mechanisms are very reliable. Further, the proposed change will allow performance of the surveillance under the conditions that apply during a plant outage, which is preferable to performance, in part, with the plant at power, as is currently necessitated by the present six month interval surveillance requirement.

Although an interlock mechanism failure would not affect air lock sealing capabilities and would therefore not directly affect containment integrity, performance of the surveillance with the plant at power, when containment integrity is required, carries with it the potential for loss ofcontainment integrity, should the interlock fait during testing and allow both doors to be opened simultaneously. The proposed TS change may result in an increased probability that due to the increased test frequency, an inoperable interlock mechanism could ga undetected for a longer length of time.

However in the unlikely event that as a containment entry is being made, abnormal radiation levels inside containment occur, any increase in consequences due to a radioactive release as a resuit of an inadvertent opening of both air lock doors (as could be allowed by a failed interlock mechanism and assuming violation of administrative controls) is counter-balanced by the decreased likelihood of similar events occurring when the interlock mechanism is tested at power under the current, more frequent, test requirement.

The proposed change to TS Bases 3/4.9.4 to add flexibility in routing cable and hoses through the containment personnel air lock will not affect the requirement to maintain at least one containment personnel air lock door capable of being closed. The analysis results for a fuel handling accident inside containment, as presented in Section 16.4.7.3 of the DBNPS Updated Safety Analysis Report (USAR), are well within the 10 CFR 100 guideline values. Since the analysis does not take credit for containment isolation, the status of the personnel air lock has no impact on the acceptability of the results.

Under the proposed change, in the event of a fuel handling accident, release of radioactive material will continue to be minimized since at least one personnel air lock door will remain capable of being closed.

2. Not create the possibility of a new or different kind of accident from any accident previously evaluated because no new accident initiators or assumptions are introduced by the proposed changes. The proposed changes do not involve a change to the plant design or operation and, therefore, will not introduce any new or different failure modes or initiators

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3. Not involve a significant reduction in a margin of safety.

The proposed TS change to SR 4.6.1.3.c to increase the surveillance interval for the air

lock interlock mechanism will have no adverse e.ffect on plant safety based on its good historical surveillance and maintenance data, and the reduction in testing at power which will occur.

The analysis results for a fuel handling accident inside containment, as presented in the DBNPS USAR, are well within the 10 CFR 100 guideline values. Since the analysis does not take credit for containment isolation, the status of the personnel air lock has no impact on the acceptability of the results. Therefore, the proposed change to TS Bases 3/4.9.4 to add flexibility in routing cable and hoses through the containment personnel air lock will not reduce the margin of safety.

CONCLUSION: -

On the basis of the above, the Davis-Besse Nuclear Power Station has determined thr.t the License Amendment Request does not constitute e 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, 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_ Operating License NPF-3, Appendix A Tectinical Specifications through Amendment 215.

. 2. DBNPS Updated Safety Analysis Report through Revision 20, 3.- NUREG-1430, " Improved Standard Technical Specifications for Babcock and Wilcox Pressurized Water Reactors," Revision 1, April,1995.

- 4. - NRC Letter to Florida Power and Light Company dated May I!,1995 " Turkey Point Uwts 3 and 4 -Issuance of Amendments RE: Requirements During Core Alterations (TAC Nos. M90679 and M90680)."

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