View source for L-14-407, Request to Amend Technical Specification 5.5.15, Containment Leakage Rate Testing Program

{{Adams
| number = ML14353A349
| issue date = 12/19/2014
| title = Request to Amend Technical Specification 5.5.15, Containment Leakage Rate Testing Program
| author name = Lieb R
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000346
| license number = NPF-003
| contact person = 
| case reference number = L-14-407
| document type = Letter type:L, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specifications
| page count = 14
}}

=Text=
{{#Wiki_filter:FENOC'                                                                                     5501 North State Route 2 Oak Harbor, Ohio 43449 FirstEnergy Nuclear Operating Company Raymond A. Lieb                                                                                       419-321-7676 Vice President, Nuclear                                                                          Fax: 419-321-7582 December 19, 2014 L-14-407                                                              10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Request to Amend Technical Specification 5.5.15, "Containment Leakage Rate Testing Program" Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) is requesting an amendment to the Davis-Besse Nuclear Power Station (DBNPS)
Technical Specification 5.5.15, "Containment Leakage Rate Testing Program."
An evaluation of the proposed amendment is provided as an enclosure. FENOC is requesting Nuclear Regulatory Commission (NRC) staff approval by January 6, 2016, and an implementation period of 45 days following issuance of the amendment.
There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 315-6810.
I declare undeJ penalty of perjury that the foregoing is true and correct. Executed on December/![!:, 2014.

==Enclosure:==
Evaluation of Proposed License Amendment cc:     NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board

EVALUATION OF PROPOSED LICENSE AMENDMENT Page 1 of 8

==Subject:==
Request to Amend Technical Specification 5.5.15, "Containment Leakage Rate Testing Program," to Incorporate a Revised Performance-Based Option for Type C Containment Isolation Valve Leakage Rate Testing 1.0    

==SUMMARY==
DESCRIPTION 2.0    DETAILED DESCRIPTION 2.1     Technical Specification 5.5.15 2.2     Proposed Changes to Technical Specification 5.5.15

==3.0    TECHNICAL EVALUATION==

3.1     NRC Limitations and Conditions 3.1.1   June 25, 2008 NRC Safety Evaluation 3.1.2 May 8, 2012 NRC Safety Evaluation 3.2     Conclusion

==4.0    REGULATORY EVALUATION==

4.1      Significant Hazards Consideration 4.2      Applicable Regulatory Requirements I Criteria 4.3      Conclusions

==5.0   ENVIRONMENTAL CONSIDERATION==

Attachments:
: 1. Proposed Technical Specification Changes (MARK-UP)
: 2. Proposed Technical Specification Changes (RETYPED)

Page 2 of 8 1.0     

==SUMMARY==
DESCRIPTION Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) hereby requests an amendment to the Davis-Besse Nuclear Power Station (DBNPS) facility operating license.
The proposed amendment would revise DBNPS Technical Specification (TS) 5.5.15, "Containment Leakage Rate Testing Program," to adopt the Type C testing portion of the guidance in Revision 3-A of the Nuclear Energy Institute (NEI) topical report NEI 94-01, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J."
The purpose of the NEI 94-01 guidance is to assist licensees in the implementation of "Option B - Performance-Based Requirements" of 10 CFR 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," (hereafter referred to as Appendix J, Option B).
Revision 3-A of NEI 94-01 added guidance for extending containment isolation valve (Type C) local leak rate test (LLRT) surveillance intervals beyond 60 months.
This amendment would allow for extended test intervals for Type C valves up to 75 months, based on the provisions of NEI 94-01, Revision 3-A.
2.0     DETAILED DESCRIPTION 2.1     Technical Specification 5.5.15 TS 5.5.15, "Containment Leakage Rate Testing Program," currently states that:
: a. A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program,"
dated September, 1995, as modified by the following exceptions:
: 1. A reduced duration Type A test may be performed using the criteria and Total Time method specified in Bechtel Topical Report BN-TOP-1, Revision 1.
: 2. The fuel transfer tube blind flanges (containment penetrations 23 and 24) will not be eligible for extended test frequencies. Their Type B test frequency will remain at 30 months. However, as-found testing will not be required.

Page 3 of 8 2.2      Proposed Changes to Technical Specification 5.5.15 The proposed amendment would change TS 5.5.15.a to indicate that for Type C tests, the program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," and that for Type A and Type B tests, the program shall be in accordance with the guidelines of Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995.
The proposed amendment would also change TS 5.5.15.a by deleting an unnecessary comma between "September" and "1995." This change is editorial and is not further discussed in the technical evaluation.
The proposed TS changes are marked in Attachment 1; the TS retyped pages incorporating the proposed changes are provided in Attachment 2.

==3.0      TECHNICAL EVALUATION==

3.1      NRC Limitations and Conditions Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program,"
(September 1995) provides a method acceptable to the NRC for implementing the performance-based option (Option B) of 10 CFR 50, Appendix J. The regulatory positions for Type C testing stated in Regulatory Guide 1.163 (September 1995), as modified by NRC safety evaluations of June 25, 2008 (ADAMS Accession No. ML081140105) and May 8, 2012 [forwarded to NEI by letter dated June 8, 2012]
(ADAMS Accession No. ML121030286), are incorporated in topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J." The FENOC response to the limitations and conditions on using NEI 94-01, as discussed in the June 25, 2008 and May 8, 2012 NRC safety evaluations, is provided below.
3.1.1     June 25. 2008 NRC Safety Evaluation The six limitations and conditions from the June 25, 2008 safety evaluation, Section 4.1, "Limitations and Conditions for NEI [topical report] TR 94-01, Revision 2," are not applicable for the following reasons:
* FENOC is not proposing a change to any Type A testing requirement
* DBNPS is not licensed under 10 CFR Part 52 Similar to the discussion on Section 4.1, the four conditions in Section 4.2, "Limitations and Conditions for EPRI Report No. 1009325, Revision 2," ["Risk-Impact Assessment of Extended Integrated Leak Rate Testing Intervals"] are not applicable.

Page 4 of 8 3.1.2      May 8, 2012 NRC Safety Evaluation The two conditions from Section 4.0 of the May 8, 2012 safety evaluation [forwarded to NEI by NRC correspondence dated June 8, 2012] are stated below, followed by the FENOC response for DBNPS.
Condition 1 NEI TR 94-01, Revision 3, is requesting that the allowable extended interval for Type C LLRTs be increased to 75 months, with a permissible extension (for non-routine emergent conditions) of nine months (84 months total). The staff is allowing the extended interval for Type C LLRTs be increased to 75 months with the requirement that a licensee's post-outage report include the margin between the Type Band Type C leakage rate summation and its regulatory limit. In addition, a corrective action plan shall be developed to restore the margin to an acceptable level. The staff is also allowing the non-routine emergent extension out to 84 months as applied to Type C valves at a site, with some exceptions that must be detailed in NEI 94-01, Revision 3. At no time shall an extension be allowed for Type C valves that are restricted categorically (e.g. BWR MSIVs), and those valves with a history of leakage, or any valves held to either a less than maximum interval or to the base refueling cycle interval. Only non-routine emergent conditions allow an extension to 84 months. This is Topical Report Condition 1.
FENOC Response to Condition 1 This condition has been incorporated in NEI 94-01, Revision 3-A, Section 10.1 and Section 12.1. With the proposed amendment to perform Type C testing in accordance with NEI 94-01, Revision 3-A, this condition will be met in the future.
Condition 2 The basis for acceptability of extending the ILRT interval out to once per 15 years was the enhanced and robust primary containment inspection program and the local leakage rate testing of penetrations. Most of the primary containment leakage experienced has been attributed to penetration leakage and penetrations are thought to be the most likely location of most containment leakage at any time. The containment leakage condition monitoring regime involves a portion of the penetrations being tested each refueling outage, nearly all LLRT's being performed during plant outages. For the purposes of assessing and monitoring or trending overall containment leakage potential, the as-found minimum pathway leak rates for the just tested penetrations are summed with the as-left minimum pathway leak rates for penetrations tested during the previous 1 or 2 or even 3 refueling outages.
Type C tests involve valves which, in the aggregate, will show increasing leakage potential due to normal wear and tear, some predictable and some not so predictable. Routine and appropriate maintenance may extend this increasing leakage potential. Allowing for longer intervals between LLRTs means that more leakage rate test results from farther back in time are summed with fewer just tested penetrations and that total used to assess the current containment leakage potential.
This leads to the possibility that the LLRT totals calculated understate the actual leakage potential of the penetrations. Given the required margin included with the

Page 5 of 8 performance criterion and the considerable extra margin most plants consistently show with their testing, any understatement of the LLRT total using a 5-year test frequency is thought to be conservatively accounted for. Extending the LLRT intervals beyond 5 years to a 75-month interval should be similarly conservative provided an estimate is made of the potential understatement and its acceptability determined as part of the trending specified in NEI 94-01, Revision 3, Section 12.1.
When routinely scheduling any LLRT valve interval beyond 60 months and up to 75 months, the primary containment leakage rate testing program trending or monitoring must include an estimate of the amount of understatement in the Type B and Type C total, and must be included in a licensee's post-outage report. The report must include the reasoning and determination of the acceptability of the extension, demonstrating that the LLRT totals calculated represent the actual leakage potential of the penetrations. This is Topical Report Condition 2.
FENOC Response to Condition 2 This condition has been incorporated in NEI 94-01, Revision 3-A, Section 11.3.2 and Section 12 .1. With the proposed amendment to perform Type C testing in accordance with NEI 94-01, Revision 3-A, this condition will be met in the future.
3.2     Conclusion NEI 94-01, Revision 3-A, describes an NRG-accepted approach for implementing the performance-based requirements of Appendix J, Option B. It incorporates the regulatory positions stated in Regulatory Guide 1.163 and includes provisions for extending Type C test intervals to 75 months.
Implementation of this program revision at DBNPS will permit application of extended test intervals for Type C valves that meet the provisions of NEI 94-01, Revision 3-A.

==4.0     REGULATORY EVALUATION==

4.1     Significant Hazards Consideration The proposed amendment to Davis-Besse Nuclear Power Station (DBNPS), Technical Specification (TS) 5.5.15, "Containment Leakage Rate Testing Program," would change TS 5.5.15.a to indicate that for Type C tests, the program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," and that for Type A and Type B tests, the program shall be in accordance with the guidelines of Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995. The proposed amendment would also change TS 5.5.15.a by deleting an unnecessary comma between "September" and "1995."

Page 6 of 8 FirstEnergy Nuclear Operating Company has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed amendment adopts the NRG-accepted guidelines of NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," for DBNPS performance-based Type C containment isolation valve testing. Revision 3-A of NEI 94-01 allows, based on previous valve leak test performance, an extension of Type C containment isolation valve leak test intervals.
Since the change involves only performance-based Type C testing, the proposed amendment does not involve either a physical change to the plant or a change in the manner in which the plant is operated or controlled.
Implementation of these guidelines continues to provide adequate assurance that during design basis accidents, the components of the primary containment system will limit leakage rates to less than the values assumed in the plant safety analyses.
The proposed amendment will not change the leakage rate acceptance requirements.
As such, the containment will continue to perform its design function as a barrier to fission product releases.
Therefore, the proposed amendment does not significantly increase the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed amendment to revise the extended frequency performance-based Type C testing program does not change the design or operation of structures, systems, or components of the plant.
The proposed amendment would continue to ensure containment operability and would ensure operation within the bounds of existing accident analyses. There are no accident initiators created or affected by the proposed amendment.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

Page 7 of 8
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed amendment to revise the extended frequency performance-based Type C testing program does not affect plant operations, design functions, or any analysis that verifies the capability of a structure, system, or component of the plant to perform a design function. In addition, this change does not affect safety limits, limiting safety system setpoints, or limiting conditions for operation.
The specific requirements and conditions of the Technical Specification Containment Leakage Rate Testing Program exist to ensure that the degree of containment structural integrity and leak-tightness that is considered in the plant safety analysis is maintained.
The overall containment leak rate limit specified by Technical Specifications is maintained, thus ensuring the margin of safety in the plant safety analysis is maintained.
The design, operation, testing methods, and acceptance criteria for Type A, Type B, and Type C containment leakage tests specified in applicable codes and standards would continue to be met with the acceptance of this proposed change, since these are not affected by this revision to the performance-based containment testing program.
Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.
Based on the above, FirstEnergy Nuclear Operating Company concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
4.2      Applicable Regulatory Requirements I Criteria The proposed amendment has been evaluated to determine whether applicable regulations and requirements continue to be met.
10 CFR 50.54(0) requires primary reactor containments for water-cooled power reactors to be subject to the requirements of Appendix J to 10 CFR 50, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors." Appendix J specifies containment leakage testing requirements, including the types required to ensure the leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values.
Appendix J also specifies that periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during their service life. In addition, Appendix J discusses leakage rate test methodology, frequency of testing, and reporting requirements for each type of test.
Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program,"
(September 1995) provides a method acceptable to the NRC for implementing the performance-based option (Option B) of 10 CFR 50, Appendix J. The regulatory

Page 8 of 8 positions for Type C tests stated in Regulatory Guide 1.163 (September 1995) as modified by NRG Safety Evaluations of June 25, 2008 (ADAMS Accession No. ML081140105) and May 8, 2012 (ADAMS Accession No. ML121030286) are incorporated in Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J."
The proposed license amendment would revise DBNPS Technical Specification 5.5.15, "Containment Leakage Rate Testing Program," Item a, by changing the wording to indicate that the program for Type C tests will be in accordance with NEI 94-01, Revision 3-A, instead of Regulatory Guide 1.163.
The purpose of NEI 94-01 is to assist licensees in the implementation of Option B to 10 CFR Part 50, Appendix J. In the May 8, 2012 Safety Evaluation (SE), the NRG staff documented that the technical positions outlined in the SE are consistent with the regulations and established staff positions, while providing more detailed discussion concerning the methodology and data required to support surveillance testing frequencies.
The NRG staff reviewed NEI 94-01, Revision 3, and found that this guidance, as modified to include two limitations and conditions, is acceptable for referencing by licensees proposing to amend their Technical Specifications in regards to containment leakage rate testing.
Based on the foregoing, the proposed amendment will continue to ensure compliance with 10 CFR 50.54(0), and Option B of 10 CFR Part 50, Appendix J.
4.3      Conclusions In conclusion, based on the considerations discussed above, (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 continue to be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

==5.0      ENVIRONMENTAL CONSIDERATION==

An examination of the three criteria provided in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Section (c)(9) determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Therefore, pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Attachment 1 Proposed Technical Specification Changes (MARK-UP)
(2 Pages Fallow)

Programs and Manuals 5.5 5.5    Programs and Manuals 5.5.14         Safety Function Determination Program (continued)
: 3. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and
: 4. Other appropriate limitations and remedial or compensatory actions.
: b. A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable; and INSERT: For Type C tests, this program shall be in supported by the accordance with the guidelines contained in Nuclear r
Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing             in turn supported by the Performance-Based Option of 10 CFR Part 50,                     ; or Appendix J," dated July 2012. For Type A and Type B tests, this                                                     stem(s) for the 5.5.14.b.1 and
: c. The SFDP identifies here a loss of safety function exists. If a loss of safety function is dete ined to exist by this program, the appropriate Conditions and Require Actions of the LCO in which the loss of safety function exists are requi d to be entered. When a loss of safety function is caused by the inoperabili of a single Technical Specification support system, the appropriate C ditions and Required Actions to enter are those of the support system.
5.5.15
: a. A program shall establish the le kage rate testing of the containment as required by 10 CFR 50.54(0) a        0 CFR 50, Appendix J, Option B, as modified by approved exemptions. ~program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September~1995, as modified by the following exceptions:
: 1. A reduced duration Type A test may be performed and Total Time method specified in Bechtel Topical BN-TOP-1, Revision 1.
DELETE: comma (,)
Davis-Besse                                    5.5-12                              Amendment~

Programs and Manuals 5.5 FOR INFORMATION ONLY PROVIDED FOR CONTEXT 5.5.15       Containment Leakage Rate Testing Program (continued)
: 2. The fuel transfer tube blind flanges (containment penetrations 23 and
: 24) will not be eligible for extended test frequencies. Their Type B test frequency will remain at 30 months. However, as-found testing will not be required.
: b. The calculated peak containment internal pressure for the design basis loss of coolant accident, Pa, is 38 psig.
: c. The maximum allowable containment leakage rate, La, at Pa, shall be 0.50% of containment air weight per day.
: d. Leakage rate acceptance criteria are:
: 1. Containment leakage rate acceptance criterion is < 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and C tests and ::; 0. 75 La for Type A tests.
: 2. Air lock testing acceptance criteria are:
a)     Overall air lock leakage rate is::; 0.015 La when tested at::::: Pa.
b)     For each door, leakage rate is::; 0.01 La when the volume between the door seals is pressurized to ::::: 10 psig.
: e. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.
5.5.16      Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, including the following:
: a. Actions to restore battery cells with float voltage < 2.13 V;
: b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates; and
: c. Actions to verify that the remaining cells are > 2.07 V when a pilot cell or cells have been found to be < 2.13 V.
5.5.17      Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE Davis-Besse                                    5.5-13                              Amendment 279

Attachment 2 Proposed Technical Specification Changes (RETYPED)
(1 Page Follows)

Programs and Manuals 5.5 5.5   Programs and Manuals
~~~~~~~~~~~~~~~~**"1-Qn...tP:CrQJO[!r:&sect;a.mm (continued)
RETYPED - FOR INFORMATION ONLY
---------!"11'--ll"l"l'~!ft"l'l"i~~~             re that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and
: 4. Other appropriate limitations and remedial or compensatory actions.
: b. A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable; and
: 1. A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or
: 2. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or
: 3. A required system redundant to the support system(s) for the supported systems described in Specifications 5.5.14.b.1 and 5.5.14.b.2 above is also inoperable.
: c. The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.
5.5.15       Containment Leakage Rate Testing Program
: a. A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. For Type C tests, this program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J,"
dated July 2012. For Type A and Type B tests, this program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, as modified by the following exceptions:
: 1. A reduced duration Type A test may be performed using the criteria and Total Time method specified in Bechtel Topical Report BN-TOP-1, Revision 1.
Davis-Besse                                  5.5-12                             Amendment

FENOC'                                                                                     5501 North State Route 2 Oak Harbor, Ohio 43449 FirstEnergy Nuclear Operating Company Raymond A. Lieb                                                                                       419-321-7676 Vice President, Nuclear                                                                          Fax: 419-321-7582 December 19, 2014 L-14-407                                                              10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Request to Amend Technical Specification 5.5.15, "Containment Leakage Rate Testing Program" Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) is requesting an amendment to the Davis-Besse Nuclear Power Station (DBNPS)
Technical Specification 5.5.15, "Containment Leakage Rate Testing Program."
An evaluation of the proposed amendment is provided as an enclosure. FENOC is requesting Nuclear Regulatory Commission (NRC) staff approval by January 6, 2016, and an implementation period of 45 days following issuance of the amendment.
There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 315-6810.
I declare undeJ penalty of perjury that the foregoing is true and correct. Executed on December/![!:, 2014.

==Enclosure:==
Evaluation of Proposed License Amendment cc:     NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board

EVALUATION OF PROPOSED LICENSE AMENDMENT Page 1 of 8

==Subject:==
Request to Amend Technical Specification 5.5.15, "Containment Leakage Rate Testing Program," to Incorporate a Revised Performance-Based Option for Type C Containment Isolation Valve Leakage Rate Testing 1.0    

==SUMMARY==
DESCRIPTION 2.0    DETAILED DESCRIPTION 2.1     Technical Specification 5.5.15 2.2     Proposed Changes to Technical Specification 5.5.15

==3.0    TECHNICAL EVALUATION==

3.1     NRC Limitations and Conditions 3.1.1   June 25, 2008 NRC Safety Evaluation 3.1.2 May 8, 2012 NRC Safety Evaluation 3.2     Conclusion

==4.0    REGULATORY EVALUATION==

4.1      Significant Hazards Consideration 4.2      Applicable Regulatory Requirements I Criteria 4.3      Conclusions

==5.0   ENVIRONMENTAL CONSIDERATION==

Attachments:
: 1. Proposed Technical Specification Changes (MARK-UP)
: 2. Proposed Technical Specification Changes (RETYPED)

Page 2 of 8 1.0     

==SUMMARY==
DESCRIPTION Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) hereby requests an amendment to the Davis-Besse Nuclear Power Station (DBNPS) facility operating license.
The proposed amendment would revise DBNPS Technical Specification (TS) 5.5.15, "Containment Leakage Rate Testing Program," to adopt the Type C testing portion of the guidance in Revision 3-A of the Nuclear Energy Institute (NEI) topical report NEI 94-01, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J."
The purpose of the NEI 94-01 guidance is to assist licensees in the implementation of "Option B - Performance-Based Requirements" of 10 CFR 50, Appendix J, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors," (hereafter referred to as Appendix J, Option B).
Revision 3-A of NEI 94-01 added guidance for extending containment isolation valve (Type C) local leak rate test (LLRT) surveillance intervals beyond 60 months.
This amendment would allow for extended test intervals for Type C valves up to 75 months, based on the provisions of NEI 94-01, Revision 3-A.
2.0     DETAILED DESCRIPTION 2.1     Technical Specification 5.5.15 TS 5.5.15, "Containment Leakage Rate Testing Program," currently states that:
: a. A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program,"
dated September, 1995, as modified by the following exceptions:
: 1. A reduced duration Type A test may be performed using the criteria and Total Time method specified in Bechtel Topical Report BN-TOP-1, Revision 1.
: 2. The fuel transfer tube blind flanges (containment penetrations 23 and 24) will not be eligible for extended test frequencies. Their Type B test frequency will remain at 30 months. However, as-found testing will not be required.

Page 3 of 8 2.2      Proposed Changes to Technical Specification 5.5.15 The proposed amendment would change TS 5.5.15.a to indicate that for Type C tests, the program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," and that for Type A and Type B tests, the program shall be in accordance with the guidelines of Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995.
The proposed amendment would also change TS 5.5.15.a by deleting an unnecessary comma between "September" and "1995." This change is editorial and is not further discussed in the technical evaluation.
The proposed TS changes are marked in Attachment 1; the TS retyped pages incorporating the proposed changes are provided in Attachment 2.

==3.0      TECHNICAL EVALUATION==

3.1      NRC Limitations and Conditions Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program,"
(September 1995) provides a method acceptable to the NRC for implementing the performance-based option (Option B) of 10 CFR 50, Appendix J. The regulatory positions for Type C testing stated in Regulatory Guide 1.163 (September 1995), as modified by NRC safety evaluations of June 25, 2008 (ADAMS Accession No. ML081140105) and May 8, 2012 [forwarded to NEI by letter dated June 8, 2012]
(ADAMS Accession No. ML121030286), are incorporated in topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J." The FENOC response to the limitations and conditions on using NEI 94-01, as discussed in the June 25, 2008 and May 8, 2012 NRC safety evaluations, is provided below.
3.1.1     June 25. 2008 NRC Safety Evaluation The six limitations and conditions from the June 25, 2008 safety evaluation, Section 4.1, "Limitations and Conditions for NEI [topical report] TR 94-01, Revision 2," are not applicable for the following reasons:
* FENOC is not proposing a change to any Type A testing requirement
* DBNPS is not licensed under 10 CFR Part 52 Similar to the discussion on Section 4.1, the four conditions in Section 4.2, "Limitations and Conditions for EPRI Report No. 1009325, Revision 2," ["Risk-Impact Assessment of Extended Integrated Leak Rate Testing Intervals"] are not applicable.

Page 4 of 8 3.1.2      May 8, 2012 NRC Safety Evaluation The two conditions from Section 4.0 of the May 8, 2012 safety evaluation [forwarded to NEI by NRC correspondence dated June 8, 2012] are stated below, followed by the FENOC response for DBNPS.
Condition 1 NEI TR 94-01, Revision 3, is requesting that the allowable extended interval for Type C LLRTs be increased to 75 months, with a permissible extension (for non-routine emergent conditions) of nine months (84 months total). The staff is allowing the extended interval for Type C LLRTs be increased to 75 months with the requirement that a licensee's post-outage report include the margin between the Type Band Type C leakage rate summation and its regulatory limit. In addition, a corrective action plan shall be developed to restore the margin to an acceptable level. The staff is also allowing the non-routine emergent extension out to 84 months as applied to Type C valves at a site, with some exceptions that must be detailed in NEI 94-01, Revision 3. At no time shall an extension be allowed for Type C valves that are restricted categorically (e.g. BWR MSIVs), and those valves with a history of leakage, or any valves held to either a less than maximum interval or to the base refueling cycle interval. Only non-routine emergent conditions allow an extension to 84 months. This is Topical Report Condition 1.
FENOC Response to Condition 1 This condition has been incorporated in NEI 94-01, Revision 3-A, Section 10.1 and Section 12.1. With the proposed amendment to perform Type C testing in accordance with NEI 94-01, Revision 3-A, this condition will be met in the future.
Condition 2 The basis for acceptability of extending the ILRT interval out to once per 15 years was the enhanced and robust primary containment inspection program and the local leakage rate testing of penetrations. Most of the primary containment leakage experienced has been attributed to penetration leakage and penetrations are thought to be the most likely location of most containment leakage at any time. The containment leakage condition monitoring regime involves a portion of the penetrations being tested each refueling outage, nearly all LLRT's being performed during plant outages. For the purposes of assessing and monitoring or trending overall containment leakage potential, the as-found minimum pathway leak rates for the just tested penetrations are summed with the as-left minimum pathway leak rates for penetrations tested during the previous 1 or 2 or even 3 refueling outages.
Type C tests involve valves which, in the aggregate, will show increasing leakage potential due to normal wear and tear, some predictable and some not so predictable. Routine and appropriate maintenance may extend this increasing leakage potential. Allowing for longer intervals between LLRTs means that more leakage rate test results from farther back in time are summed with fewer just tested penetrations and that total used to assess the current containment leakage potential.
This leads to the possibility that the LLRT totals calculated understate the actual leakage potential of the penetrations. Given the required margin included with the

Page 5 of 8 performance criterion and the considerable extra margin most plants consistently show with their testing, any understatement of the LLRT total using a 5-year test frequency is thought to be conservatively accounted for. Extending the LLRT intervals beyond 5 years to a 75-month interval should be similarly conservative provided an estimate is made of the potential understatement and its acceptability determined as part of the trending specified in NEI 94-01, Revision 3, Section 12.1.
When routinely scheduling any LLRT valve interval beyond 60 months and up to 75 months, the primary containment leakage rate testing program trending or monitoring must include an estimate of the amount of understatement in the Type B and Type C total, and must be included in a licensee's post-outage report. The report must include the reasoning and determination of the acceptability of the extension, demonstrating that the LLRT totals calculated represent the actual leakage potential of the penetrations. This is Topical Report Condition 2.
FENOC Response to Condition 2 This condition has been incorporated in NEI 94-01, Revision 3-A, Section 11.3.2 and Section 12 .1. With the proposed amendment to perform Type C testing in accordance with NEI 94-01, Revision 3-A, this condition will be met in the future.
3.2     Conclusion NEI 94-01, Revision 3-A, describes an NRG-accepted approach for implementing the performance-based requirements of Appendix J, Option B. It incorporates the regulatory positions stated in Regulatory Guide 1.163 and includes provisions for extending Type C test intervals to 75 months.
Implementation of this program revision at DBNPS will permit application of extended test intervals for Type C valves that meet the provisions of NEI 94-01, Revision 3-A.

==4.0     REGULATORY EVALUATION==

4.1     Significant Hazards Consideration The proposed amendment to Davis-Besse Nuclear Power Station (DBNPS), Technical Specification (TS) 5.5.15, "Containment Leakage Rate Testing Program," would change TS 5.5.15.a to indicate that for Type C tests, the program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," and that for Type A and Type B tests, the program shall be in accordance with the guidelines of Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995. The proposed amendment would also change TS 5.5.15.a by deleting an unnecessary comma between "September" and "1995."

Page 6 of 8 FirstEnergy Nuclear Operating Company has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed amendment adopts the NRG-accepted guidelines of NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J," for DBNPS performance-based Type C containment isolation valve testing. Revision 3-A of NEI 94-01 allows, based on previous valve leak test performance, an extension of Type C containment isolation valve leak test intervals.
Since the change involves only performance-based Type C testing, the proposed amendment does not involve either a physical change to the plant or a change in the manner in which the plant is operated or controlled.
Implementation of these guidelines continues to provide adequate assurance that during design basis accidents, the components of the primary containment system will limit leakage rates to less than the values assumed in the plant safety analyses.
The proposed amendment will not change the leakage rate acceptance requirements.
As such, the containment will continue to perform its design function as a barrier to fission product releases.
Therefore, the proposed amendment does not significantly increase the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed amendment to revise the extended frequency performance-based Type C testing program does not change the design or operation of structures, systems, or components of the plant.
The proposed amendment would continue to ensure containment operability and would ensure operation within the bounds of existing accident analyses. There are no accident initiators created or affected by the proposed amendment.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

Page 7 of 8
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed amendment to revise the extended frequency performance-based Type C testing program does not affect plant operations, design functions, or any analysis that verifies the capability of a structure, system, or component of the plant to perform a design function. In addition, this change does not affect safety limits, limiting safety system setpoints, or limiting conditions for operation.
The specific requirements and conditions of the Technical Specification Containment Leakage Rate Testing Program exist to ensure that the degree of containment structural integrity and leak-tightness that is considered in the plant safety analysis is maintained.
The overall containment leak rate limit specified by Technical Specifications is maintained, thus ensuring the margin of safety in the plant safety analysis is maintained.
The design, operation, testing methods, and acceptance criteria for Type A, Type B, and Type C containment leakage tests specified in applicable codes and standards would continue to be met with the acceptance of this proposed change, since these are not affected by this revision to the performance-based containment testing program.
Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.
Based on the above, FirstEnergy Nuclear Operating Company concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.
4.2      Applicable Regulatory Requirements I Criteria The proposed amendment has been evaluated to determine whether applicable regulations and requirements continue to be met.
10 CFR 50.54(0) requires primary reactor containments for water-cooled power reactors to be subject to the requirements of Appendix J to 10 CFR 50, "Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors." Appendix J specifies containment leakage testing requirements, including the types required to ensure the leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values.
Appendix J also specifies that periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during their service life. In addition, Appendix J discusses leakage rate test methodology, frequency of testing, and reporting requirements for each type of test.
Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program,"
(September 1995) provides a method acceptable to the NRC for implementing the performance-based option (Option B) of 10 CFR 50, Appendix J. The regulatory

Page 8 of 8 positions for Type C tests stated in Regulatory Guide 1.163 (September 1995) as modified by NRG Safety Evaluations of June 25, 2008 (ADAMS Accession No. ML081140105) and May 8, 2012 (ADAMS Accession No. ML121030286) are incorporated in Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J."
The proposed license amendment would revise DBNPS Technical Specification 5.5.15, "Containment Leakage Rate Testing Program," Item a, by changing the wording to indicate that the program for Type C tests will be in accordance with NEI 94-01, Revision 3-A, instead of Regulatory Guide 1.163.
The purpose of NEI 94-01 is to assist licensees in the implementation of Option B to 10 CFR Part 50, Appendix J. In the May 8, 2012 Safety Evaluation (SE), the NRG staff documented that the technical positions outlined in the SE are consistent with the regulations and established staff positions, while providing more detailed discussion concerning the methodology and data required to support surveillance testing frequencies.
The NRG staff reviewed NEI 94-01, Revision 3, and found that this guidance, as modified to include two limitations and conditions, is acceptable for referencing by licensees proposing to amend their Technical Specifications in regards to containment leakage rate testing.
Based on the foregoing, the proposed amendment will continue to ensure compliance with 10 CFR 50.54(0), and Option B of 10 CFR Part 50, Appendix J.
4.3      Conclusions In conclusion, based on the considerations discussed above, (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 continue to be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

==5.0      ENVIRONMENTAL CONSIDERATION==

An examination of the three criteria provided in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Section (c)(9) determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Therefore, pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Attachment 1 Proposed Technical Specification Changes (MARK-UP)
(2 Pages Fallow)

Programs and Manuals 5.5 5.5    Programs and Manuals 5.5.14         Safety Function Determination Program (continued)
: 3. Provisions to ensure that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and
: 4. Other appropriate limitations and remedial or compensatory actions.
: b. A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable; and INSERT: For Type C tests, this program shall be in supported by the accordance with the guidelines contained in Nuclear r
Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing             in turn supported by the Performance-Based Option of 10 CFR Part 50,                     ; or Appendix J," dated July 2012. For Type A and Type B tests, this                                                     stem(s) for the 5.5.14.b.1 and
: c. The SFDP identifies here a loss of safety function exists. If a loss of safety function is dete ined to exist by this program, the appropriate Conditions and Require Actions of the LCO in which the loss of safety function exists are requi d to be entered. When a loss of safety function is caused by the inoperabili of a single Technical Specification support system, the appropriate C ditions and Required Actions to enter are those of the support system.
5.5.15
: a. A program shall establish the le kage rate testing of the containment as required by 10 CFR 50.54(0) a        0 CFR 50, Appendix J, Option B, as modified by approved exemptions. ~program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September~1995, as modified by the following exceptions:
: 1. A reduced duration Type A test may be performed and Total Time method specified in Bechtel Topical BN-TOP-1, Revision 1.
DELETE: comma (,)
Davis-Besse                                    5.5-12                              Amendment~

Programs and Manuals 5.5 FOR INFORMATION ONLY PROVIDED FOR CONTEXT 5.5.15       Containment Leakage Rate Testing Program (continued)
: 2. The fuel transfer tube blind flanges (containment penetrations 23 and
: 24) will not be eligible for extended test frequencies. Their Type B test frequency will remain at 30 months. However, as-found testing will not be required.
: b. The calculated peak containment internal pressure for the design basis loss of coolant accident, Pa, is 38 psig.
: c. The maximum allowable containment leakage rate, La, at Pa, shall be 0.50% of containment air weight per day.
: d. Leakage rate acceptance criteria are:
: 1. Containment leakage rate acceptance criterion is < 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and C tests and ::; 0. 75 La for Type A tests.
: 2. Air lock testing acceptance criteria are:
a)     Overall air lock leakage rate is::; 0.015 La when tested at::::: Pa.
b)     For each door, leakage rate is::; 0.01 La when the volume between the door seals is pressurized to ::::: 10 psig.
: e. The provisions of SR 3.0.3 are applicable to the Containment Leakage Rate Testing Program.
5.5.16      Battery Monitoring and Maintenance Program This Program provides for battery restoration and maintenance, including the following:
: a. Actions to restore battery cells with float voltage < 2.13 V;
: b. Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates; and
: c. Actions to verify that the remaining cells are > 2.07 V when a pilot cell or cells have been found to be < 2.13 V.
5.5.17      Control Room Envelope Habitability Program A Control Room Envelope (CRE) Habitability Program shall be established and implemented to ensure that CRE habitability is maintained such that, with an OPERABLE Control Room Emergency Ventilation System (CREVS), CRE Davis-Besse                                    5.5-13                              Amendment 279

Attachment 2 Proposed Technical Specification Changes (RETYPED)
(1 Page Follows)

Programs and Manuals 5.5 5.5   Programs and Manuals
~~~~~~~~~~~~~~~~**"1-Qn...tP:CrQJO[!r:&sect;a.mm (continued)
RETYPED - FOR INFORMATION ONLY
---------!"11'--ll"l"l'~!ft"l'l"i~~~             re that an inoperable supported system's Completion Time is not inappropriately extended as a result of multiple support system inoperabilities; and
: 4. Other appropriate limitations and remedial or compensatory actions.
: b. A loss of safety function exists when, assuming no concurrent single failure, no concurrent loss of offsite power, or no concurrent loss of onsite diesel generator(s), a safety function assumed in the accident analysis cannot be performed. For the purpose of this program, a loss of safety function may exist when a support system is inoperable; and
: 1. A required system redundant to the system(s) supported by the inoperable support system is also inoperable; or
: 2. A required system redundant to the system(s) in turn supported by the inoperable supported system is also inoperable; or
: 3. A required system redundant to the support system(s) for the supported systems described in Specifications 5.5.14.b.1 and 5.5.14.b.2 above is also inoperable.
: c. The SFDP identifies where a loss of safety function exists. If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered. When a loss of safety function is caused by the inoperability of a single Technical Specification support system, the appropriate Conditions and Required Actions to enter are those of the support system.
5.5.15       Containment Leakage Rate Testing Program
: a. A program shall establish the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. For Type C tests, this program shall be in accordance with the guidelines contained in Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 3-A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J,"
dated July 2012. For Type A and Type B tests, this program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program," dated September 1995, as modified by the following exceptions:
: 1. A reduced duration Type A test may be performed using the criteria and Total Time method specified in Bechtel Topical Report BN-TOP-1, Revision 1.
Davis-Besse                                  5.5-12                             Amendment}}