ML20236K432

Safety Evaluation Supporting Amend 224 to License NPF-03

ML20236K432
Person / Time
Site:	Davis Besse
Issue date:	06/30/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236K426	List: ML20236K423 ML20236K432
References
NUDOCS 9807090316
Download: ML20236K432 (7)

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UNITED STATES g

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NUCLEAR REGULATORY COMMISSION 2

WASHINGTON, D.C. 20006 4001 l

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0. 224 TO FACILITY OPERATING LICENSE NO. NPF-3 TOLEDO EDIS0N COMPANY CENTERIOR SERVICE COMPANY MQ THE CLEVELAND ELECTRIC ILLUMINATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION. UNIT NO. 1 DOCKET NO. 50-346

1.0 INTRODUCTION

By letter dated December 23, 1997, as supplemented by letter dated June 11, 1998, Toledo Edison Company, Centerior Service Company, and The Cleveland Electric Illuminating Company (the licensees), submitted a request for changes to the Davis-Besse Nuclear Power Station, Unit No.1, Technical Specifications (TSs).

The proposed amendment would revise Technical Specification (TS) Section 1.0,

" Definitions," to clarify the meaning of core alteration; would relocate TS Section 3/4.9.5, " Refuel W Operations - Communications," and the associated bases to the Techfical Requirements Manual; and would add TS Section 3.0.6 and associated bases to address the return to service of inoperable equipment.

2.0 BACKGROUND

Since several of the proposed TS changes are independent, necessary background for each is provided in the evaluation.

3.0 LICENSING BASIS The licensing basis for the systems affected by the proposed changes includes:

3.1 Davis-Besse Updated Safety Analysis Report (USAR) Section 9.5.2,

" Communications Systems" l

USAR Section 9.5.2 describes the offsite and onsite communication cystems at Davis-Besse.

Specifically, Section 9.5.2.2.3 discusses the separate loop circuit for the exclusive use of personnel directly involved with fuel handling operations.

This system provides direct communication between the control room and the fuel handling area.

l 9807090316 980630 PDR ADOCK 05000346 P

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3.2 USAR Section 15.4.7, " Fuel-Handling Accident."

l This USAR'section presents the analysis of a fuel-handling accident.

l Accidents inside and outside of containment are considered,' including accidents involving fuel in dry cask storage.

4.0 EVALUATION l

The licensees are proposing several TS changes.

Each proposed change is l

evaluated below..

4.1 TS Index Paae VIII The licensees are proposing to delete the word " Communications," replacing it l

with the word " Deleted." This is an administrative change consistent with the other changes in this amendment request.

Therefore, it is acceptable.

4.2 TS Index Paae XII (Bases)

The licensees are proposing to delete the word " Communications," replacing it with the word " Deleted." This is also an administrative change consistent l

with the other changes in.this amendment request.

Therefore, it is l

acceptable.

4.3 TS Definitions 1.12. Core Alteration i

The licensees are. proposing to clarify the definition of core alteration.

TS 1.12 currently reads:

CORE ALTERATION shall be the movement or manipulation of any component within the reactor pressure vessel with the vessel head removed and fuel l

in the vessel. Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe conservative position.

The licensees are proposing to remove the words "or manipulation," " pressure,"

and " conservative," and to add " fuel. sources. or reactivity control" and "L" so that TS 1.12 would read:

CORE ALTERATION shall be the movement of any fuel. sources. 'or reactivity control componenth within the reactor vessel with the vessel head removed and fuel in the vessel.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a component to a safe position.

This proposed change removes terms which are redundant or could be confusing, and adds clarifying details. The staff has determined that these alterations mak6 the definition easier to understand without changing the meaning.

Therefore, this change is acceptable.

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l 4.4 TS 3/4.0. "Limitina Conditions for Operation and Surveillance l

Requirements - Acolicability" and Associated Bases The licensees are proposing to add TS 3.0.6, which reads:

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l Equipment removed from service or declared inoperable to comply with ACTIONS ray be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to Specification l

3.0.2 for the system returned to service under administrative control to l

perform the testing required to demonstrate OPERABILITY.

The licensees are also proposing to add TS Bases 3.0.6, which reads:

Specification 3.0.6 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from l

service or declared inoperable to comply with ACTIONS.

The sole purpose.

l of this Specification is to provide an exception to Specification 3.0.2 (e.g., to not comply with the applicable Required Action (s)) to allow the performance of required testing to demonstrate:

a.

The OPERABILITY of the equipment being returned to service; or j

b.

The OPERABILITY of other equipment.

The administrative controls ensure the time the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the required testing to demonstrate OPERABILITY. This Specification does not provide time to l

perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions, and must be reopened to perform the required testing.

l An example of demonstrating the OPERABILITY of other equipment being returned to service is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occurring i

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during the performance of required testing on another channel in the other trip system.

f. similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of required testing on l

another channel in the same trip system.

Davis-Besse TS 3.0.2 states:

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Adherence to the requirements of the Limiting Condition for Operation

[LC0] and/or associated ACTION within the specified time interval shall J

constitute' compliance with the specification.

In the event the Limiting l

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Condition for Operation is restored prior to expiration of the specified time interval, completion of the ACTION statement is not required.

This TS defines compliance for each TS LC0 and/or associated action. By this definition, if an LC0 has been entered due to a faulty component, and as part of the associated action, the component is removed from service and repaired, and if the component is returned to service prior to being demonstrated operable, then the licensees are in violation of the TSs.

Often, the only reasonal,le way to demonstrate operability is to put the component in service and test it, in violation of the TSs. The licensees are proposing to add TS 3.0.6 to provide an exception to TS 3.0.2, as described in the proposed TS 3.0.6 and bases quoted above. This exception would only be valid for necessary testing to demonstrate operability, and administrative controls would be in place to ensure that the time for this testing would be minimized and no other actions would be taken.

The NRC staff position on this. issue was stated in a letter to Niagara Mohawk Power Corporation dated November 21, 1996. This letter states:

It is not the intent of TS 3.0.2 to preclude the return to service of a component that has been replaced or repaired when it can reasonably be considered operable except for the completion of surveillance testing to confirm its operability. The NRC staff has addressed this existing ambiguity in TS 3.0.2 by adding TS 3.0.5 [ identical in wording to the above proposed'TS 3.0.6] to the Standard Technical Specifications (STS) for BWR/4, Revision 1 (also added to the Babcock and Wilcox STS, Revision 1].

This letter goes on to state:

In addition to providing this clarification, the Bases for TS 3.0.5

'[ identical to wording to the proposed TS 3.0.6 Bases, with the exception noted below] also notes that the administrative controls are to ensure that the time during which the component-is under manual control of the operator before operability is demonstrated is to be limited to the minimum time necessary to perform the allowed surveillance (i.e., this is not to include time for other preventive or corrective maintenance).

As. stated above, the proposed TS 3.0.6 and Bases text is identical to the STS, Revision 1, text, with one exception. The licensees have included the NRC-approved change to the Bases (Traveller for STS Revision 2 Changes, TSTF-165 dated May 5, 1997) to refer to " required testing" and "to demonstrate operability."

The staff has determined the proposed change to include TS 3.0.6 and its bases clarifies an ambiguity in the TSs, and is consistent with the current staff

. position on this TS, including the May 5, 1997 change. Therefore, the proposed change is acceptable.

i 4.5 TS 3/4.9.5. "Refuelina Operations - Communications" and Associated Bases j

The licensees propose to relocate TS 3/4.9.5 and the associated bases in their entirety to the Davis-Besse Technical Requirements Manual (TRM), a licensee-controlled document referenced in the USAR and controlled through the 10 CFR 50.59 change process.

The licensees committed to complete the relocations to the TRM concurrently with the removals from the TSs.

This TS currently states:

LIMITING CONDITION FOR OPERATION 3.9.5 Direct communication shall be maintained between the control room and personnel at the refueling station.

APPLICABILITY:

During CORE ALTERATIONS.

I ACTION:

When direct communications between the control room and personnel at the refutling station cannot be maintained, suspend all CORE ALTERATIONS.

The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE RE0VIREMENTS 4.9.5 Direct communications between the control room and personnel at the refueling station shall be demonstrated within one hour prior to the start of and at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during CORE ALTERATIONS.

The bases currently state:

The requirement for communications capability ensures that refueling station personnel can be promptly informed of significant changes in the facility status or core reactivity condition during CORE ALTERATIONS.

Guidance to evaluate the scope of the technical specifications is provided in 10 CFR 50.36, as follows:

Criterion 1:

Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Criterion 2:

l A process variable, design feature, or operating restriction that is an l

initial condition of a Design Basis Accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

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Criterion 3:

A structure, system, or component that.is part of the primary success 4

path and which functions or actuates to mitigate a Design Basis Accident or transient that either assumes the failure of or presents a challenge to the integrity of a' fission product barrier.

Criterion 4:

A structure, system,.or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Requirements that are in the existing TSs, but do not meet the guidance set forth in 10 CFR 50.36 for inclusion in TS, can be relocated to appropriate licensee-controlled documents.

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criterion 1. The communication system is not instrumentation. Therefore, this criterion does not apply.

Criterion 2 The communication system is not a process variable, design.

feature or operating restriction. Therefore, this criterion does not apply.

Criterion 3 The communication system is not a structure or a component. As a system,.it does not function or actuate to mitigate a design basis accident or transient. Therefore, this criterion does not apply.

Criterion 4 The communication system is not a structure or a component. As a system, it has not been shown by operating experience or probabilistic safety assessment to be significant to public health and safety. Therefore, Criterion.4 does not require the inclusion of the communication system in TSs.

Since TS 3/4.9.5 and the associated bases do not satisfy any of the four criteria from 10 CFR 50.36, they may be proposed for. removal.

Further, the

= facility and procedures described in the FSAR TRM (to which the TS and bases would be relocated) can only be revised under the provisions of 10 CFR 50.59, which ensures an auditable and appropriate control over the relocated requirements and future changes to these provisions.

The staff has determined that relocation of TS 3/4.9.5 and the associated bases to the TRM.is consistent with the criteria in 10 CFR 50.36, with the 10 CFR 50.59 process providing appropriate controls for future changes.

Therefore, the proposed. relocation is acceptable.

5.0 STATE CONSULTATION

In accordance with the Comission's regulations, the Ohio State official was notified of the proposed issuance of the amendment. The State official had no

. comments.

6.0 ENVIRONMENTAL CONSIDERATION

This amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 or changes 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 effluent 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 the amendment involves no significant hazards consideration, and there has been no public comment on such finding (63 FR 4327).

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to

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10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 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; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) 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:

A. Hansen Date: Jime 30,1998

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