ML20205C501

Application for Amend to License NPF-3,correcting Clerical Error in Action Statement of Tech Spec Section 3.7.9.1 to Make Reporting Requirements Consistent W/Reporting Requirements Concept in Fire Protection Tech Specs

ML20205C501
Person / Time
Site:	Davis Besse
Issue date:	08/05/1986
From:	Williams J TOLEDO EDISON CO.
To:
Shared Package
ML20205C419	List: ML20205C414 ML20205C501 ML20205C512
References
TAC-62221, NUDOCS 8608120340
Download: ML20205C501 (5)

Text

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i APPLICATION FOR AMENDMENT l

TO FACILITY OPERATING LICENCE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Enclosed are forty-three (43) copies of the requested change to the Davis-Besse Nuclear Power Station Unit No. 1 Facility Operating License No. NPF-3. Also included are the Safety Evaluation and Significant Hazards Consideration.

The proposed change (submitted under cover letter Serial No. 1286) affects:

4 Section 3/4.7, Plant Systems, Limiting Condition for Operation, 3.7.9.1, Action Statement "a".

i By /s/-J. Williams, Jr.

Senior Vice President, Nuclear Sworn and subscribed before me this 5th day of August, 1986.

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/s/ Laurie A. Hinkle Notary Public, State of Ohio My Commission Expires May 15, 1991

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8608120340 860805 PDR P

ADOCK 05000346 PDR

Dockat No. 50-346 License No. NPF-3 Serial No. 1286 August 5, 1986 The following information is provided to support issuance of the requested change to the Davis-Besse Nuclear Power Station Unit No. 1, Operating License NPF-3, Appendix A, Technical Specifications, Section 3.7.9.1, Action Statement "a".

A. Time Required to Implement: This change is to be effective thirty (30) days following NRC issuance of the License Amendment.

B. Reason for Change (Facility Change Request 86-197):,In Toledo Edison's submittal, dated December 16, 1984 (Serial No. 1108), in re-sponse to NRC Generic Letter 83-43, the word "or" was erroneously deleted in Action Statement "a" of Section 3.7.9.1. This clerical error was incorporated into Amendment No. 93 (Log No. 1960). To correct this error and maintain consistency with fire protection Technical Specifications Sections 3.3.3.8b, 3.7.9.2a and 3.7.10a, which were correctly revised under Amendment No. 93, Toledo Edison has determined that the word "or" which was deleted should be reinserted.

C. Safety Evaluation: See attached Safety Evaluation.

D. Significant Hazards Consideration: See attached Significant Hazards Consideration.

Docket No. 50-346 License No. NPF-3 Serial No. 1286 August 5, 1986 Attachment SAFETY EVALUATION On December 16, 1984 Toledo Edison submitted a license amendment request (Serial No. 1108) to the NRC incorporating the revised reporting require-ments of 10 CFR Part 50, Sections 50.72 and 50.73 pursuant to the direction

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of NRC Generic Letter 83-43. This request was approved by the NRC and issued as Amendment No. 93 to the Davis-Besse Nuclear Power Station Unit No. 1 Technical Specifications. However, Toledo Edison's request contained a clerical error which was incorporated into Amendment No. 93. As discussed below, the purpose of this amendment request is to correct this error.

Proposed Revision The safety function of Technical Specification 3/4.7.9 is to provide limiting technical conditions for plant operation and surveillance re-quirements concerning the fire suppression water system. Section 3.7.9.1, Action Statement "a" presently requires that a special report be prepared in accordance with Section 6.9.2 regardless of the duration of time for which the equipment is inoperable. This resulted from the word "or" inadvertently being deleted on the marked up Technical Specification pages in Toledo Edison's request of Serial No. 1108.

The insertion of the word "or" after the words "...within 7 days,..." in the Action Statement "a" of Section 3.7.9.1 will correct the error. This correction will eliminate the inadvertent requirement that Toledo Edison must file a special report with the NRC even if the inoperable equipment is returned to operable status within 7 days. This revision will make the reporting requirements of Action Statement "a" of Section 3.7.9.1 consis-tent with the reporting requirements concept of the action statements to fire protection Technical Specifications Sections 3.3.3.8b, 3.7.9.2a, and 3.7.10a. These sections were correctly revised under Amendment No. 93.

The insertion of the word "or" will also make the requirement under which a report must be submitted consistent with the requirements of the B&W Standard Technical Specifications, NUREG-0103, Revision 4 (

Reference:

Technical Specification 3/4.7.11).

Discussion of Unreviewed Safety Question The implementation of the proposed revision 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, as this revision affects ,

only an administrative reporting requirement.  !

2. Create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report.

This revision is administrative and does not involve creation of an accident or malfunction.

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Dockat No. 50-346 License No. NPF-3 Serial No. 1286 August 5, 1986 Attachment

3. Reduce the margin of safety as defined in the basis for any Technical Specifications. The margin of safety is not reduced by this adminis-trative change in reporting to the NRC.

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

i Docket Ns. 50-346 License No. NPF-3 ,

Serial No. 1286 i August 5, 1986 Attachment SIGNIFICANT HAZARDS CONSIDERATION The safety function of Technical Specification 3/4.7.9 is to provide limiting technical conditions for plant operation and surveillance re-quirements concerning the fire suppression water system. Section 3.7.9.1, Action Statement "a" presently requires that a special report be prepared in accordance with Section 6.9.2 regardless of the duration of time for which the equipment is inoperable. This resulted from the word "or" inadvertently being deleted on the marked up Technical Specification pages in Toledo Edison's request of Serial No. 1108 dated December 16, 1984.

The insertion of the word "or" after the words "...within 7 days,..." in Action Statement "a" of Section 3.7.9.1 will correct the error. This correction will eliminate the inadvertent requirement that Toledo Edison must file a special report with the NRC even if the inoperable equipment is returned to operable status within 7 days. This revision will make the reporting requirements of Action Statement "a" of Section 3.7.9.1 consis-tent with the reporting requirements concept of the action statements to fire protection Technical Specification Sections 3.3.3.8b, 3.7.9.2a, and 3.7.10a. These sections were correctly revised under Amendment No. 93 (Log No. 1960). The insertion of the word "or" will also make the require-ment under which a report must be submitted consistent with the requirements of the B&W Standard Technical Specifications, NUREG-0103, Revision 4.

The granting of the request would not:

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

The addition of the word "or" to the Action Statement does not increase the probability or consequences of an accident previously evaluated, but, rather, affects only an administrative reporting requirement.

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

The revised Action Statement does not create a new or different kind of accident from any accident previously evaluated. The revision of the Action Statement is administrative and does not involve creation of an accident.

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

The margin of safety is not reduced by this Technical Specification change which is an administrative change in reporting.

On the basis of the above, Toledo Edison has determined that the amendment request does not involve a significant hazards consideration.

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