ML20236M941
| ML20236M941 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/07/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20236M935 | List: |
| References | |
| NUDOCS 9807140335 | |
| Download: ML20236M941 (6) | |
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k UNITED STATES p
g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. ensan met SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 225 TO FACILITY OPERATING LICENSE NO. NPF-3 TOLED0 EDIS0N COMPANY CENTERIOR SERVICE COMPANY E
i THE CLEVELAND ELECTRIC ILLUMINATING COMPANY i
DAVIS-BESSE NUCLEAR POWER STATION. UNIT NO. 1 1
DOCKET NO. 50-316.
1.0 INTRODUCTION
By letter dated April 24, 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 change Technical Specification (TS) Section 3/4.3.1.1, " Reactor Protection System Instrumentation," TS Section 3/4.3.2.1,
" Safety Features Actuation System Instrumentation," TS Section 3/4.3.2.2,
" Steam and Feedwater Rupture Control System Instrumentation," and the associated TS bases.
The TS tables of response time limits would be relocated to the Davis-Besse Technical Requirements Manual (TRM). Other changes in
-these TS sections consistent with the relocation are also proposed.
2.0 LICENSING BASIS-
'In addition to the affected TSs, the licensing basis for the systems affected by the proposed changes includes Davis-Besse Updated Safety Analysis Report (USAR) Section 7, " Instrumentation and Control." Separate sections describe the Reactor Protection System (RPS), the Safety Features Actuation System (SFAS), and the Steam and Feedwater Line Rupture Control System (SFRCS).
3.0 EVALUATION As stated in the USAR, the RPS initiates a reactor trip when a sensed parameter exceeds a setpoint value, indicating the approach of an unsafe condition. The SFAS prevents or limits fission product and energy release from the core, isolates the containment vessel, and initiates operation of safety equipment in the. event of a loss-of-coolant accident. The SFRCS is l
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.. designed to prevent the release of high energy steam, to start the auxiliary
.feedwater. system when appropriate, and to prevent steam generator overfill and subsequent spillover into the main steam lines.
It also provides a trip signal to the anticipatory reactor trip system.-
'The licensees are proposing to relocate the TS tables of response time limits for:these systems to the Davis-Besse TRM, which is referenced in the USAR.
This is a' licensee-controlled document which can be changed subject to 10 CFR
'50.59,1" Changes, tests and experiments." The licensees are also proposing to remove references in the TSs to these tables and to move the applicable portions of footnotes in the tables to the TSs. The licensees have also proposed changes to the associated TS Bases. The licensees committed to complete the relocations to the TRM concurrently with the removals from the
-TSs.
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TS Table 3.3-2, Table-3.3-5 and Table 3.3-13 contain the values of the
, response time limits for the RPS, SFAS and SFRCS instruments, respectively.
l The limiting conditions for operation (LCOs) for this-instrumentation specify l
- that these systems shall be operable with the response times as listed in these tables. These limits are the acceptance criteria for the response time tests performed to satisfy the surveillance requirements of TS 4.3.1.1 (RPS),
l TS 4.3.2.1 (SFAS) and TS 4.3.2.2 (SFRCS) for each applicable function. These surveillance ensure that the response times of the instruments are consistent with the assumptions of the safety analyses performed for design basis accidents and transients.
l The changes proposed by the licensees involve only the relocation of the l
. response time tables but retain the surveillance requirements to perform response time testing. The proposed relocation does not alter the TS requirements to ensure that the response times of'the instruments are within
.their limits, though the USAR will now contain the acceptance criteria for the required response time surveillance.
The staff has concluded that relocation of the response time limit tables for
'RPS, SFAS and SFRCS'from the TSs to the USAR is acceptable. This determination is based on the fact that the removal of the specific response time tables does not eliminate the requirements for the licensees to ensure L
that-the' protection instrumentation is capable of performing its safety function. ' Although the tables are relocated to the USAR, the licensees must l
continue to evaluate any changes to response time requirements in accordance with:10 CFR 50.59.
In reaching this conclusion, the staff determined that 10 CFR 50.36, I
= Technical Specifications," does not require the response time tables to be retained in the TSs. The response times are an operational detail related to the licensees' safety analysis and are adequately controlled by the L
requirements of 10 CFR 50.59. Therefore, the continued processing of license l-amendments related to revisions of the affected instrument or component response times would afford no significant benefit with regard to protecting the.public health and safety.
Further, the. response time requirements do not constitute a condition or limitation on operation necessary to minimize the possibility of an abnormal situation or event giving rise to an immediate l
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threat to the public health and safety, because the ability of the systems to perform their safety functions is not adversely impacted by the relocation of cthe tables.
Each proposed change to the TSs and TS bases for RPS, SFAS and SFRCS is evaluated below.
3.1 TS 3.3.1.1. " Reactor Protection System Instrumentation - Limitina Condition for Operation"
-TS 3.3.1.1 currently states:
As a minimum, the Reactor Protection System instrumentation channels and bypasses of Table 3.3-1 shall be OPERABLE. with RESPONSE TIMES as shown i
in Table 3.3-2.
i The licensees propose to delete the phrase ". with RESPONSE TIMES as shown in 1
- Table 3.3-2."
As stated in Section 3.3 below, Table 3.3.2 is being relocated to the TRM, with the response times controlled under 10 CFR 50.59.
Thus, this reference is no longer applicable. This is an administrative change consistent with the other proposed changes.
Therefore, it is acceptable.
3.2 TS 4.3.1.1.3. " Reactor Protection System Instrumentation - Surveillance Requirements" The licensees are proposing to add the following caveat to TS 4.3.1.1.3:
Neutron detectors are exempt from response time testing; the response
- time of the neutron flux signal portion of the channel shall be measured from the neutron detector output or'from the input of the first electronic component in the channel.
The proposed caveat is currently in TS Table 3.3.2, which is being removed (see Section 3.3 below).
The licensees are proposing to relocate this caveat.
to TS 4.3.1.1.3.
Since this is a relocation within current TSs, it is an administrative change only, and-is acceptable.
In addition, the licensees are proposing to add the following footnote:
- The response times include the sensor (except for the neutron detectors), Reactor Protection System instrument delay, and the control rod drive breaker delay. A delay time has been assumed for the Reactor Coolant Pump monitor in the determination of the response time of the High Flux / Number of Reactor Coolant Pumps On functional unit.
l This footnote captures the descriptive part of other footnotes'in Table 3.3.2, l
L which is being removed. The quantitative part of these footnotes will be relocated to the TRM. Moving the descriptive part of these footnotes to TS'4.3.1.1.3 is a relocation within current TSs. Therefore, it is an 1 administrative change only and is acceptable.
Relocating the quantitative part~of these footnotes to the TRM is consistent with the evaluation presented in Section 3.0 above, and is therefore acceptable. This determination is
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based on the fact that the relocation does not eliminate the requirements for the-licensees to ensure that the protection instrumentation is capable of performing its safety function.-_The licensees must continue to evaluate any changes to response time requirements in accordance with 10 CFR 50.59.
3.3 TS Table 3.3-2. " Reactor' Protection System Instrumentation Resoonse Times"-
The licensees are proposing to remove this table from TSs, relocating it ))
the TRM (the footnotes in this table were evaluated in Section 3.2).
This relocation was evaluated in Section 3.0 and is acceptable.
3.4 TS'3.3.2.1. " Safety System Instrumentation - Safety Features Actuation l-System Instrumentation - Limitina Condition for Operation"
.TS 3.3.2.1 currently states:
The Safety Features Actuation System (SFAS) functional units shown in-Table 3.3-3 shall be OPERABLE with their trip setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-4, with the exception of Instrument Strings Functional Units d and e and Interlock Channels Functional Unit a which shall be set consistent with the Allowable Value column of Table 3.3-4. and with RESPONSE TIMES as shown in Table 3.3-5.
The licensees propose to delete the phrase ". with RESPONSE TIMES as shown in Table 3.3-5."
As. stated in Section 3.6 below, Table 3.3-5 is being relocated
'to the TRM, with the response times controlled under 10 CFR 50.59. Thus, this reference is no longer applicable. This'is an' administrative change consistent with the other proposed changes.
Therefore, it is acceptable.
3.5 TS 4.3.2.1.3. " Safety-System Instrumentation - Safety Features Actuation System Instrumentation -~Surveill ance Requirements" The licensees are proposing to add the following footnote to TS 4.3.2.1.3:
- The response times (exceot for manual initiation) include diesel generator starting and sequence loading delays, when applicable. The response time limit (except for manual initiation) includes movement of valves and attainment of pump.or blower discharge pressure.
This footnote is currently in TS Table 3.3-5, which is being removed (see Section 3.6). -The phrase "except for manual initiation".is being added since the footnote in Table 3.3-5' does not apply to manual initiation. Hence, moving this footnote to TS 4.3.2.1.3 is a relocation within current TSs.
Therefore, it is an administrative change only and is acceptable.
3.6 TS Table 3.3-5. " Safety Features System Resoonse Tines" The licensees are proposing to remove this table from TSs, relocating it to the TRM (the footnote in this table was evaluated _in Section 3.5). This relocation was evaluated in Section 3.0 and is acceptable.
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- 3.7 TS 3.3.2.2. " Safety System Instrumentation - Steam and Feedwater Ruoture E2ptrol System Instrumentation - Limitina Condition for Operation" TS 3.3.2.2 currently states:
The Steam and Feedwater Rupture Control System (SFRCS) instrumentation channels shown in Table 3.3-11 shall be OPERABLE with their trip setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-12, with the exception of the Steam Generator Level-Low Functional Unit which shall be set consistent with the Allowable Value column of Table 3.3-12. and with RESPONSE TIMES as shown in i
Table 3.3-13.
The licensees propose to delete the phrase ". with RESPONSE TIMES as shown in Table 3.3-13."
As stated in Section 3.9 below, Table 3.3-13 is being relocated to the TRM, with the response times controlled under 10 CFR 50.59.
Thus, this reference is no longer applicable.
This is an administrative change consistent with the other proposed changes. Therefore, it is acceptable.
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3.8 TS 4.3.2.2.3. " Safety System Instrumentation - Steam and Feedwater Ruoture Control System Instrumentation - Surveillance Requirements" The licensees are proposing to add the following footnote to TS 4.3.2.2.3:
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- The Main Steam Isolation Valves (MSIVs) response time is to be the time elapsed from the monitored variable exceeding the trip setpoint until the MSIV is fully closed.
The Turbine Stop Valves (TSVs) response time is to be the time elapsed from the main steam line low pressure 4
trip condition until the TSV is fully closed.
The content of this footnote is currently in the two footnotes in TS Table 3.3-13, which is being removed (see Section 3.9).
Hence, moving this footnote to TS 4.3.2.2.3 is a relocation within current TSs.
Therefore, it is an administrative change only and is acceptable.
3.9 TS Table 3.3-13. " Steam and Feedwater Ruoture Control System Response Times" The licensees are proposing to remove this table from TSs, relocating it to the TRM (the footnote in this table was evaluated in Section 3.8).
This relocation was evaluated in Section 3.0 and is acceptable.
3.10 TS Bases 3/4.3. " Instrumentation - 3/4.3.1 and 3/4.3.2 - Reactor Protection System and Safety System Instrumentation The licensees are proposing to add the following sentence to these bases:
The response time limits for these instrumentation systems are located in the Updateo Safety Analysis Report and are used to demonstrate OPERABILITY in accordance with each system's response time surveillance requirements.
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- This addition provides clarifying information and is consistent with the proposed TS changes.
Therefore, it is acceptable.
The licensees are also proposing to delete the following sentence from these bases:
No credit was taken in the analyses for those channels with response times indicated as not applicable.
This sentence will be relocated to the TRM.
This relocation is consistent with the proposed TS changes.
Therefore, it is acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Ohio State official was notified of the proposed issuance of the amendment.
The State official had no comments.
5.0 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 30268). Accordingly, the 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 the amendment.
6.0 CONCLUSION
The st_aff 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: July 7, 1998