ML20078M598

Application for Amend to License NPF-3,changing Tech Spec Sections 4.1.2.1,4.1.2.2,3.1.2.8 & 3.1.2.9 to Extend Time for Temp Verification During & After Transport of Demineralized Water & Low Boron Concentration Liquid

ML20078M598
Person / Time
Site:	Davis Besse
Issue date:	10/11/1983
From:	Crouse R TOLEDO EDISON CO.
To:
Shared Package
ML20078M567	List: ML20078M562 ML20078M598 ML20078M620
References
TAC-51388, NUDOCS 8310250235
Download: ML20078M598 (7)

Text

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-3 APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Enclosed are forty-three (43) copies of the requested changes to the Davis-Besse Nuclear Power Station Unit No. 1 Facility Operating License No. NPF-3, together with the Safety Evaluation for the requested change.

The proposed changes include Sections 4.1.2.1, 4.1.2.2, 3.1.2.8 and 3.1.2.9.

By ((

Vice President, Nuclear l

Sworn and subscribed before me this lith day of October , 1933 ,

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Notary Publji gg Notary Public, State of Ohio My CommisAn Expires Sept.1.1987 0310250235 831011 PDR ADOCK 05000346 P pm

Docket No. 50-346 License No. NPF-3 Serial No. 994' October 11, 1983 l Attachment I. Changes to Davis-Besse Nuclear Power Station Unit 1, Appendix A, Technical Specifications Sections 4.1.2.1, 4.1.2.2., 3.1.2.8 and 3.1.2.9.

A. Time required to Implement. This change is to be effective upon NRC approval.

B. Reason for. Change (Facility Change Request 82-111 Rev. C) l The surveillance requirement for boration system requires the heat traced portion of the flow path to be verified greater than 105'F. If the system is transferring or just after trans-fer of desineralized water and low boron concentration of liquids less than 5000 ppa the piping may be less than 105'F.

The change would extend the time for verification up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

This verification of temperature also verifies the operability of the associated heat tracing.

C. Safety Evaluation l (See Attached) l D. Significant Hazard Consideration (See Attached) dh d/6-3 s

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SAFETY EVALUATION The purpose of the affected amendment request is to provide assurance against boron crystallization in the concentrated boric acid addition system and the boron injection flow path from this system. The safety function of the boric acid addition system is to provide a boration capability sufficient to ensure adequate shutdown margin from all opera-ting conditions to 1.0% AK/K after Xenon decay and cooldown to 200*F.

Technical Specifications Sections 4.1.2.1, 4.1.2.2, 3.1.2.8 and 3.1.2.9 require that two ficw paths be operaule by verifying that Lhe pipe temper-ature of the heat traced portion of the flow path from the concentrated boric acid storage system is greater than 105'F and the boric acid addi-l-

tion system and associated heat tracing has between 7,875 and 13,125 ppm of boron with a solution temperature greater than 105*F. The 105*F minimum boric acid solution temperature for the boric acid flow path is intended to avoid crystallization of the boric acid solution by maintain-ing the heat traced portion of the flow path from the concentrated boric acid solution temperature above 105'F. However, Technical Specifications 4.1.2.la and 4.1.2.2a should be revised because a section of the heat traced piping from the Boric Acid Addition Tank (BAAT) to the "T" connec-tion to the letdown return line is used not only for boric acid addition a from BAAT but also for the transport of demineralized water and other low boron concentration (<5000 ppm) liquid e.g. the clean radwaste receiver tank. Because of the relatively low temperature (60-80*F) of this low boron concentration liquid, the requirements of Specifications 4.1.2.la

! :nd 4.1.2.2a cannot be satisfied if the flow path is being used for transport of such liquids. Therefore, this surveillance requirement needs to be modified per the attached.

The only time the need for temperature verification exists is during and after the flow path has been used for transporting boric acid with a source concentration of >5000 ppmB. If at any time the line is used for transporting the boric acid of source concentration <5000 ppmB, the temperature need not be maintained above 105'F, since per the attached Figure 2 the crystallization will occur only below the freezing point of approximately 32*F. Thus, there is no safety concern for boric acid crystallirstion under those circumstances. Liquid samples are taken from ,

the source for verification of boron concentration (not from the flow path) and this is so reflected in the revised Technical Specifications. ~ '

The proposed modification to the Technical Specifications allows for ' )

conditions when the verification of surveillance requirements is to be l completed close to a time when the flow path has been or is being used to '

l transport low boron concentration solutions. Thus, if the seven day '

verification of temperature falls during transfers of low boron concen-tration solutions, the verification period may be extended up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the addition of' dilute boron solution has been stopped for at 1 cast 8 additional hours. This implies that the seven day temperature verifi-cation is not required if the line is being used for transport of low boron concentration water either continuously, or, intermittently as long l as the time period between two successive (low boron concentration) water l transports is less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This period is considered adequate and l

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included in the Technical Specifications to allow for the conduct of successive routine deborations during normal plant operation and core life. If the seven day verification falls during such transfers and the transfer is stopped for more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, the surveillance verification has to be performed within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This allows adequate time for the heat tracing to elevate and maintain the boric acid flow path temperature after the passage of cold liqaids through the flow path has been stopped. Such verification will also ensure the operability of the

' heat tracing and further, will prevent baron crystallization should the

' flow path be used next for transfers of high boron concentration solutions.

If the seven day verification falls during high boron concentration

(>5000 ppmB) transfers, the verification requirement will be the same as in the existing Technical Specifications.

Technical Specifications 3.1.2.8a 3 and 3.1.2.9a.3 require that the boric acid addition system and associated heat tracing have a minimum solution temperature of 105'F. However, as stated above, the revised Technical Specifications 4.1.2.la and 4.1.2.2a will ensure the operability of heat tracing and verification thereof on a periodic basis. Therefore, Technical Specifications 3.1.2.8a.3 and 3.1.2.9a.3 should not include the associated i

heat traced portion since the Surveillance Requirements for its operability are already included in revised Technical Specifications 4.1.2.la and 4.1.2.2a.

The proposed changes to the Technical Specifications will ensure that adequate protection is available when required. At the same time it will ,

eliminate an undue restriction on temperature during the times when this l restriction does not serve any safety function. The proposed changes adequately provide the assurance that the ' intent of the Technical Specifications is being met. Therefore, making these changes in the Technical Specifications will preserve the safety function of the boron injection system.

Pursuant to the above, this is not an unreviewed safety question.

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SIGNIFICANT HAZARD CONSIDERATION' The attached amendment request for a change to the " Limiting Condition for Operation" (LCO) and Surveillance Requirements does not contain a Significant Hazard. The proposed request allows an extension up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to verify the pipe temperature of the heat traced portion if makeup water or dilute bocon solution is being transferred and delete the oper-ability of the associated heat tracing of the boric acid addition system.

Technical Specifications Sections 4.1.2.1 and 4.1.2.2 require flow path shall be demonstrated operable by verifying that the pipe temperature of the heat traced portion of'the flow path is >105*F from the concentrated boric acid storage system. The heat traced piping from the Boric Acid Addition Tank (BAAT) to the "T" connection to the letdown return line is used not only for boric acid addition from BAAT but also for the transport of demineralized water and other low boron concentration (<5000 ppm) liquid e.g. the clean radwaste receiver tank. Because of the relatively low temperature (60-80*F) of this low boron concentration liquid, the requirements of Specifications 4.1.2.la and 4.1.2.2a cannot be satisfied if the flow path is being used for transport of such liquids.

The only time the need for temperature verification exists is during and '

after the flow path has been used for transporting boric acid with a source concentration of >5000 ppmB. If at any time the line is used for transporting the boric acid of source concentration <5000 ppmB, the temperature need not be maintained above 105*F, since the crystallization

.will occur only below the freezing point of approximately 32*F. Thus, there is no safety concern for boric acid crystallization under those

circumstances.

- The proposed modification to the Technical Specifications allows for conditions when the verification of surveillance requirements is to be completed close to a time when the flow path has been or is being used to transport low boron concentration solutions. Thus, if the seven day verification of temperature falls during transfers of low boron concen-tration solutions, the verification period may be extended up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after the addition of dilute boron solution has been stopped for at least 8 additional hours. This period is considered adequate and included in the Technical Specifications to allow for the conduct of successive routine deborations during normal plant operation.

The verification will also ensure the operability of the heat tracing and further, will prevent boron crystallization should the flow path be used next for transfers of high bcron concentration solutions. If the seven day verification falls during high boron concentration (>5000 ppmB) transfers, the verification requirement will be the same as in the exist-ing Technical Specifications.

Technical Specifications 3.1.2.8a.3 and 3.1.2.9a.3 require that the boric acid addition system and associated heat tracing have a minimum solution temperature of 105'F. However, as stated above, the revised Technical Specifications 4.1.2.la and 4.1.2.2a will ensure the operability of heat tracing and verification thereof on a period basis. Therefore, Technical 4

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Specification 3.1.2.8a.3 and 3.1.2.9a.3 should not include the associated heat traced portion since the Surveillance Requirements for its operability are already included in revised Technical Specifications 4.1.2.la and 4.1.2.2a.

The granting of the request would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated 10 CFR 50.92 (c)(1).

This revision would allow an extension to, verify the temperature of the heat traced portion ol' the horic acid system which also verifles the operability of the heat tracing. There is no significant increase in the probability or consequences of an accident previously evaluated.

2. Create the possibility of a new or different kind of accident pre-viously evaluated 10 CFR 50.92 (c)(2).

All-accidents are still bounded by previous evaluations and no new accidents are involved.

3. Involve a significant reduction in a margin of safety 10 CFR 50.92 (c)(3).

The margins of safety assumed in the accident analysis are unaffected by the request.

Therefore, based on the attached safety evaluation and the above, the requested amendment does act contain a significant hazard.

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