ML20204C733

Application for Amend to License NPF-3,consisting of Tech Spec Changes Re Deletion of Unnecessary Reporting & Requirements Re Primary Coolant Activity

ML20204C733
Person / Time
Site:	Davis Besse
Issue date:	03/17/1987
From:	Shelton D TOLEDO EDISON CO.
To:
Shared Package
ML20204C541	List: ML20204C537 ML20204C733 ML20204C783
References
TAC-64970, NUDOCS 8703250355
Download: ML20204C733 (8)

Text

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1 APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Enclosed are the requested changes to the Davis-Besse Nucles: Power Station, Unit 1, Facility Operating License No. NPF-3. Also included are the Safety Evaluation and Significant Hazards Consideration.

The proposed changes (submitted under cover letter Serial No. 1345) concern:

Section 3/4.4.8, Reactor Coolant System Specific Activity; Bases Section 3/4.4.8, Reactor Coolant System Specific Activity; Section 6.9.1.5c, Annual Operating Report.

By D. C. Shelton Vice President, Nuclear Sworn to and subscribed before me this 17th day of March, 1987.

M E[A .

1M k Notary Public, State' of Ohio My c,mmission expires %-

8703250355 870317 PDR ADOCK 05000346 P PDR

Docket No. 50-346 License No. NPF-3 Serial No. 1345 Attachment The following information is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License No. NPF-3, Appendix A, Technical Specifica-tions Section 3/4.4.8, Reactor Coolant System Specific Activity, Section 6.9.1.5, Annual Operating Report and Bases Section 3/4.4.8, Reactor Coolant System Specific Activity.

A. Time Required to Implement:

This change is to be effective thirty (30) days following NRC issuance of the License Amendment.

B. Reasons for Change (Facility Change Request 85-0285, Revision B):

The proposed changes are being submitted in response to Generic Letter No. 85-19 (Log No. 1829) which addresses the deletion of unnecessary reporting and Technical Specification requirements related to primary coolant activity associated with iodine spiking.

This application requests that the reporting requirements for iodine spiking be reduced from a short-term report to an item which is to be included in the Annual Operating Report. This application also requests that the requirements be deleted to shut down the plant if coolant activity limits are exceeded for 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period.

C. Safety Evaluation:

See attached Safety Evaluat. ion.

D. Significant Hazards Consideration:

See attached Significant Hazards Consideration.

N,

Docket Na.~50-346

~ 'i _ License.No'. NPF-3 tSerial No. 1345' Attachment 1 Page.1-SAFETY EVALUATION INTRODUCTION:

This License Amendment Request is to; revise the action statements and the reporting requirements contained in the Davis-Besse Nuclear Power Station, Unit No. 1 Operating License, Appendix'A, Technical Specifica-tion Section 3/4.4.8,-Reactor Coolant System Specific Activity. The revised reporting requirements are. incorporated into the annual reporting requirements in Technical Specification Section 6.9.1.5.

REFERENCES:

Generic Letter No. 85-19 (Log No. 1829), Reporting Requirements on Primary 1 Coolant Iodine Spikes-PROPOSED AMENDMENT REQUEST DISCUSSION:

The safety function of Technical. Specification Section:3.4.8 is to limit the specific activity of the primary coolant to ensure _that the resulting two-hour thyroid' doses at the site boundary'following a steam generator tube rupture accident will not exceed an appropriately small fraction of 10CFR Part 100 guidelines. This safety function is assured by periodic monitoring of the Reactor Coolant System (RCS)' specific-activity. The safety function of Technical Specification Section 6.9.1.5 is to outline the annual reporting requirements covering the activities during the previous calendar year.

The NRC, in their effort to eliminate unnecessary Technical' Specification requirements, has determined that the existing requirements to shut down the plant if specified reactor coolant iodine activity levels are exceeded for more than 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period can be eliminated. The NRC has also determined that the short-term reporting' requirements (Licensee Event Report (LER)) relating to iodine spikes can be eliminated and that similar information can be included in the Annual Operating Report. The information to be included in the Annual Operating Report is similar to that previously required in the LER but has been changed to more clearly designate the specific activity analyses results to be included and to delete the information regarding fuel burnup by core region.

The elimination of these requirements does not constitute an unreviewed safety question for the following reasons:

I ~1. The quality of the nuclear fuel has been greatly improved over the past decade and normal coolant iodine activity in the absence of l iodine spiking is well below the Technical Specification limit.

2. The lodine activity of the RCS is periodically monitored per surveil-lance requirements given in Table 4.4-4 of Technical Specification Section 4.4.8 to verify that the activity level is less than the limits.

, Docket No. 50-346'

, License-No. NPF-3 Serial No. 1345.

Attachment 1 Page 2

3. 10CFR50.72(b)(1)(ii) requires immediate_NRC notification of events or conditions that-resulted in cladding failures exceeding design basis values.

4. Operation'during one continuous time interval with iodine activity above 1 pCi/gm dose equivalent I-131 but within maximum allowable Technical Specification limits (due to iodine spikes) is limited to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Further, the RCS is sampled more frequently until the iodine activity is restored to below the 1 pCi/gm limit. The sampling results for all the occurrences are compiled and reported to the NRC on an annual basis per Technical Specification 6.9.1.5.

5. As required in Generic - Letter No. 85-19 (Log No. 1829), the cumulative operating time with iodine activity levels above the limit will be monitored administratively and actions will be taken to maintain it at a reasonably low level (i.e., accumulated time with high iodine activity should not approach 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />).

Based on the above, the action statement "a".in Technical Specification Section 3.4.8, which requires the shutdown of the plant when the cumulative operating time of the unit with the iodine activity greater than 1 pCi/gm exceeds 10% of the unit's total operating time, can be deleted. Similarly the short-term reporting requirements in Technical Specification Section 3.4.8 are deleted and the information required by Generic Letter No. 85-19 is incorporated into Technical Specification Section 6.9.1.5, Reports Required on an Annual Basis. Additional wording is included in Technical Specification Section 3.4.8 to ensure that the reporting requirements contained in Technical Specification Section 6.9.1.5 are recognized. The bases for the Technical Specifications are changed accordingly.

UNREVIEWED SAFETY QUESTION EVALUATION:

The proposed changes are consistent with Generic Letter No. 85-19, Reporting Requirements on Primary Coolant Iodine Spikes. Implementation of these changes would not:

'1. Increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Safety Analysis Report (10CFR50.59(a)(2)(i)).

The proposed changes are consistent with Generic Letter No. 85-19 and do not involve a modification to a system, test or experiment and do not increase the probability or consequences of an accident previously evaluated.

2. Create the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report (10CFR50.59(a)(2)(ii)).

Dsckst Ns. 50-346 License No. NPF-3 Serial No. 1345 Attachment 1-Page 3 These changes do not involve a modification to a system, test or experiment. Since proper fuel management and existing reporting requirements preclude approaching iodine activity. limits' the possi- ,

bility for an accident or. malfunction of a different type than any evaluated previously in the Safety Analysis Report is not created.

3. Reduce the margin of safety as defined in the basis for any Techni-cal Specification (10CFR50.59(a)(2)(iii)).

The proposed change does not reduce the margin of safety because operation during one continuous time interval with iodine activity above the limits, but within a maximum allowable limit, is limited to forty-eight (48) hours as required in Generic Letter No. 85-19. The cumulative operating time with iodine activity above the limit will.

be monitored administratively with actions being taken to maintain it at a reasonably low level.

based on the above evaluation, it is determined that this change does not involve an unreviewed safety question.

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Docket No. 50-346

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License No. NPF-3 Serial No.-1345

' Attachment 2 PageL1 SIGNIFICANT HAZARDS CONSIDERATION INTRODUCTION:

The proposed amendment request revises the action statements and the reporting requirements contained.in the Davis-Eesse. Nuclear Power Station, Unit No. 1 Operating License, Appendix A, Technical Specification Section 3/4.'4.8, Reactor Coolant System Specific Activity.

The revised reporting requirements are incorporated into the annual reporting requirements in Technical Specification Section 6.9.1.5.

REFERENCES:

-Generic Letter No. 85-19 (Log No'. 1829), Reporting Requirements on Primary Coolant Iodine Spikes PROPOSED AMENDMENT REQUEST DISCUSSION:

The safety function of Technical Specification Section 3.4.8 is to limit the specific activity of the primary coolant to ensure that the resulting two-hour thyroid doses at the site boundary following a steam generator-tube rupture accident will not exceed an appropriately small fraction of 10CFR Part 100 guidelines. This safety function is assured by periodic monitoring of the Reactor Coolant System-(RCS) specific activity. The safety function of Technical Specification Section 6.9.1.5 is to outline the annual reporting requirements covering the

~

activities during the previous calendar year.

The NRC, in their effort to eliminate unnecessary Technical Specification requirements, has determined that the existing requirements to shut down the plant if specified reactor coolant iodine activity levels are exceeded for more than 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> in a 12-month period can be eliminated. The NRC has also. determined that the short-term reporting requirements (Licensee Event Report (LER)) relating to iodine spikes can be eliminated and that similar information can be included in the Annual Operating Report. The information to be included in the Annual Operating Report is similar to that previously required in the LER but has been changed to more clearly designste the specific activity analyses results to be included and to delete the information regarding fuel burnup by core region.

The elimination of these requirements does not constitute an unreviewed safety question for the following reasons:

1. The quality of the nuclear fuel has been greatly improved over the past decade and normal coolant iodine activity in the absence of iodine spiking is well below the Technical Specification limit.

Docket No. 50-346 License No.- NPF-3 Serial No.'1345 Attachment 2.

-Page 2

2. The f odine activity of 'the RCS is periodically _ monitored per surveil-lance requirements given in Table 4.4-4 of Technical Specification Section 4.4.8 to verify that the activity level is less than the limits.

3. 10CFR50.72(b)(1)(ii) requires immediate NRC notification'of events or. conditions that resulted in cladding failures exceeding design basis values.

4. Operation during one continuous time-interval with iodine activity above 1 pCi/gm dose equivalent I-131 but~within maximum allowable Technical Specification limits (due to iodine spikes) is. limited to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Further, the RCS is sampled more frequently until the iodine activity is restored to below the 1 pCi/gm limit. The sampling results for all the occurrences are compiled and reported to the NRC on an annual basis per Technical Specification 6.9.1.5.

5. As required in Generic Letter No. 85-19 (Log No. 1829), the cumulative operating time with iodine activity levels above the limit will be monitored administrative 1y and actions will be taken to maintain it at a reasonably low level'(i.e., accumulated time with high iodine activity should not approach 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br />).

Based on the above, the action statement "a" in Technical Specification Section 3.4.8, which requires the shutdown of the plant when the cumulative operating time of the unit with the iodine activity greater than 1 pCi/gm exceeds 10% of the unit's total operating time, can be deleted. Similarly the short-term reporting requirements in Technical Specification Section 3.4.8 are deleted and the information required by Generic Letter No. 85-19 is incorporated into Technical Specification Section 6.9.1.5, Reports Required on an Annual Basis. Additional wording is included in Technical Specification Section 3.4.8 to ensure that the reporting requirements contained in Technical Specification Section 6.9.1.5 are recognized. The bases for the Technical Specifications are changed accordingly.

BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION:

The proposed. change does not involve a significant hazards consideration because operation of Davis-Besse, Unit No. 1, in accordance with this change would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated (10CFR50.92(c)(1)).

The proposed changes are consistent with Generic Letter No. 85-19 (Log No. 1829) and do not involve a modification to a system, test or experiment and do not increase the probability or consequences of an accident previously evaluated.

Docket Na. 50-346' License No. NPF-3.

Serial No. 1345 Attachment 2 l .Page 3

2. Create the possibility of a new or different kind of accident from any previously evaluated (10CFR50.92(c)(2)).

These changes do not involve a modification to a system, test or experiment. Since proper fuel management and existing reporting requirements preclude approaching iodine activity limits, the i

possibility for a new or different kind of accident than any previously evaluated is not created.

3.. Involve a significant reduction in a margin of safety (10CFR50.92(c)(3)).

The proposed change does not reduce the margin of safety because operation during one continuous time interval with iodine activity above the limits but within a maximum allowable limit is limited to forty-eight (48)-hours as required in Technical Specification 3.4.8a, and the cumulative operating time with iodine activity above the limit will be monitored administratively, as-recommended in Generic Letter No. 85-19, with actions being taken to maintain it at a reasonably low level.

Based on the above evaluation, Toledo Edison has determined that the amendment request does not involve a significant hazards consideration.

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