ML20086A219

Application for Amend to License NPF-3.Amend Would Relocate TSs 3/4.3.3.3,3/4.3.3.4 & 3/4.4.11

ML20086A219
Person / Time
Site:	Davis Besse
Issue date:	06/23/1995
From:	Jain S CENTERIOR ENERGY
To:
Shared Package
ML20086A208	List: ML20086A207 ML20086A219 ML20086A225
References
NUDOCS 9507030109
Download: ML20086A219 (12)

Text

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1 . Dockat Nu;ber 50-346 Lic;nsa NuLb2r NPF-3

.S:ric1 Nu:bar 2295 -

Enclosure 1

.Page 1 APPLICATION FOR AMENDMENT >

TO [

FACILITY OPERATING LICENSE NPF-3 l

-DAVIS-BESSE NUCLEAR POWER STATION UNIT NUMBER 1 .

t

Attached are requested changes to the Davis-Besse Nuclear Power Station,  ;

Unit Number 1 Facility Operating License Number NPF-3. Also included is the Safety Assessment and Significant Hazards Consideration.

The proposed changes (submitted under cover letter Serial Number 2295) {

concern:  ;

Appendix A, Technical Specification Section 3/4.3.3.3 - Seismic Instrumen-  !

tation and its associated Bases.

Appendix A, Technical Specification Section 3/4.3.3.4 - Meteorological Instrumentation and its associated Bases Appendix A, Technical Specification 3/4.4.11 - Reactor Coolant System Vents and their associated Bases. i Appendix A, Technical Specification Section 6.9.2 - Special Reports For: J. P. Stetz, Vice President - Nuclear  !

By: W Ef4fT[hnd Services S. C. Jain, Director - Engineerir g l i

Sworn and subscribed before me this 23rd day of June, 1995.  ;

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i 41fl/PR) .

. i Notary Puglle,' State ol Ohio .

l EVELYNL DRESS l

Notary Pubhe, State of Ohio My Commission Empires 7/28/99 i

9507030109 950623 6  ;

PDR ADOCK 0500 P. J t

, Dock:t Nu:b;r 50-346

l. . Lictnsa Numb 2r NPF-3 S: riel Nuxbar 2295 Enclosure 1

'Page 2 The following information is provided to support issuance of the requested changes to Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1 Opera-ting License NPF-3, Appendix A, Technical Specifications. The changes involve the relocation of TS 3/4.3.3.3 - Seismic Instrumentation, TS 3/4.3.3.4 - Meteorological Instrumentation and TS 3/4.4.11 - Reactor Coolant System Vents and their Bases. These Technical Specifications are proposed for relocation to Chapter 16 of the DBNPS Updated Safety Analysis Report.

Technical Specification 6.9.2 - Special Reports contains requirements for special reports due to inoperable Seismic Monitoring Instrumentation and for inoperable Meteorological Monitoring Instrumentation. TS 6.9.2.b -

Inoperable Seismic Monitoring Instrumentation and TS 6.9.2.c - Inoperable Meteorological Monitoring Instrumentation are proposed for deletion.

A. Time Required to Implement: This change is to be implemented within 90 days after NRC issuance of the License Amendment.

B. Reason for Change (License Amendment Request 95-0012):

The TS cited above do not meet the criteria for inclusion in plant Technical Specifications and are therefore proposed for relocation.

These criteria vore published by the NRC as the " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" in the rederal Register, (58 FR 39132, dated July 22, 1993).

This application proposes changes to the TS regarding the deletion of the above mentioned TS and their relocation to Chapter 16 of the DBNPS Updated Safety Analysis Report. In general, the Technical Specifica-tions that are proposed for relocation would be incorporated into the USAR vith the same format and content they possessed as part of the Operating License, with the exception that the Special Report require-ments for inoperable Seismic Monitoring Instruments and Meteorological Monitoring Channels currently contained within the action statements vould not be required.

TS 6.9.2.b - Inoperable Seismic Monitoring Instrumentation, and TS 6.9.2.c - Inoperable Meteorological Monitoring Instrumentation, Special Reports, are proposed for deletion from the Technical Specifications, and vill not be relocated due to the removal of TS 3/4.3.3.3 and TS 3/4.3.3.4, from the operating license.

C. Safety Assessment and Significant Hazards Consideration. (See Attachment).

Dockot Numbar 50-346 License Number NPF-3 ,

' Serial Number 2295 Attachment t SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST 95-0012 (22 pages follow)

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4 LAR 95-0012 Page 1 SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSID'd RATION FOR LICENSE AMENDMENT REQUEST NUMBER 95-0012 TITLE:

Proposed Modification to the Davis-Besse Nuclear Power Station (DBNPS)

Operating License NPF-3, Appendix A Technical Specifications to Relocate Technical Specifications (TS) 3/4.3.3.3 - Seismic Instrumentation, TS 3/4.3.3.4 - Meteorological Instrumentation, and TS 3/4.4.11 - Reactor Coolant System Vents and their Bases.

DESCRIPTION: ,

The purpose of this License Amendment Request is to modify the Davis-Besse Nuclear Power Station (DBNPS) Operating License NPF-3, Appendix A Technical  :

Specifications (TS) by relocating TS 3/4.3.3.3 - Seismic Instrumentation, TS 3/4.3.3.4 - Meteorological Instrumentation, and TS 3/4.4.11 - Reactor Coolant System Vents and their Bases from the Operating License to chapter 16 of the DBNPS Updated Safety Analysis Report (USAR). The TS index is i also being revised to reflect these changes.

Technical Specification 6.9.2 - Special Reports contains a listing of TS which require submittal of special reports, including special reports due to inoperable Seismic Monitoring Instrumentation or inoperable Meteorologi-cal Monitoring Instrumentation. TS 6.9.2.b - Inoperable Seismic Monitoring Instrumentation and TS 6.9.2.c - Inoperable Meteorological Monitoring in-strumentation are proposed for deletion due to the removal of TS 3/4.3.3.3 and TS 3/4.3.3.4 from the Operating Ifeense.

Section 50.36 of Title 10 of the Code of Federal Regulations (10CFR) estab-lishes the regulatory requirements for licensees to include TS as part of applications for operating licenses. In addition, the Nuclear Regulatory Commission's " Final Policy Statement on TS Improvements for Nuclear Power Reactors," dated July 22, 1993, and other Commission documents provide guidance regarding the required content of TS. The fundamental purpose of the TS, as described in the Commission's Final Policy Statement, is to impose those conditions or limitatione upon reactor operation necessary to .

obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety. This is accomplished by identifying those features that are of controlling importance to nuclear safety and establishing on them certain conditions of operation which cannot be changed without prior Commission approval.

The Commission's Final Policy Statement recognized, as had previous state-ments related to the NRC Staff's TS Improvement Program, that implementa-tion of the policy would result in the relocation of existing TS

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i requirements to licensee-controlled documents such as the Updated Safety Analysis Report (USAR). Those' items relocated to the USAR vould in turn be controlled in accordance with the requirements of 10 CFR Section 50.59, ,

" Changes, Tests and Experiments." 10 CFR Section 50.59 provides criteria 1 to determine when facility or operating changes planned by a licensee require prior Commission approval in the form of a license amendment in order to address any unreviewed safety questions.

Four criteria vere published by the NRC in the " Final Policy Statement on TS Improvements for Nuclear Power Reactors." This NRC policy established that any TS requirements which did not meet any of the four criteria may be proposed for relocation to licensee controlled documents such as the USAR.

The TS cited above do not meet the four criteria for inclusion in the DBNPS TS and are, therefore, proposed for relocation. These relocations are also consistent with the guidance provided by the " Improved Standard Technical Specifications for Babcock and Vilcox Plants (ISTS)," NUREG-1430.

The above TS and their Bases are proposed for relocation to the DBNPS USAR Chapter 16. In general, the TS that are proposed for relocation would be incorporated into the USAR with the same format and content they possessed as part of the Operating License, with the exception that the Action State-ment Special Report requirements for inoperable Seismic Honitoring Instru-  !

ments and Meteorological Monitoring Instrumentation Channels vould not be required. Rather, the reporting criteria of 10 CFR 50.72, "Immediate Notification Requiraments for Operating Nuclear Reactors," and 10 CFR 50.73, " Licensee Event Report System," vill be evaluated and applied as necessary.

TS 6.9.2.b - Inoperable Seismic Honitoring Instrumentation, and TS 6.9.2.c Inoperable Meteorological Monitoring Instrumentation, Special Reports, are proposed for deletion from the Technical Specifications, and will not be relocated.

SYSTEMS, COMPONENTS, AND ACTIVITIES AFFECTED:

Technical Specifications and Bases for: Seismic Monitoring Instrumentation System, Meteorological Monitoring Instrumentation System, and Reactor Cool- 1 ant System Vents.

Technical Specification requirements for Special Reports due to the inoper-ability of Seismic Monitoring Instrumentation or Meteorological Monitoring Instrumentation. ,

1 FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS, AND ACTIVITIES:

The function of the Operating License Appendix A Technical Specifications is to impose those conditions or limitations upon reactor operation neces-sary to preserve the validity of the results of USAR Design Bases Accidents.

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The Seismic Monitoring Instrumentation System is described in the DBNPS USAR Section 3.7.4, " Criteria for Seismic Instrumentation Program." The l Seismic Instrumentation System is provided to promptly detect and determine the magnitude of a seismic event so that the effect on those plant features important to safety may be evaluated. This capability is provided for a comparison of the measured response to that used in the design basis for the plant. Comparison of such data is used to determine whether the plant can operate safely, and permit timely action as may be appropriate. The Seismic Monitoring Instrumentation System has no nuclear safety-related function.

The Meteorological Monitoring Instrumentation System is used to collect weather data for the DBNPS. The Meteorological Monitoring System is used ,

1 to ensure that sufficient meteorological data is available for estimating potential radiation doses to the public as a result of a routine or acci-dental release of radioactive materials to the atmosphere. This capability is used to evaluate the need for initiating protective measures. The On-Site Meteorological Measurement Program is described in DBNPS USAR Section 2.3.3. The Meteorological Monitoring Instrumentation System has no direct nuclear safety-related function.

The Reactor Coolant System Vents are described in the DBNPS USAR Section 3.5.10.2. The system provides vents on each of the two hot legs and en the pressurizer to vent noncondensible gases and steam to aid in refilling the RCS and promote natural circulation flow for core cooling. Technical Specification 3/4.4.11 - Reactor Coolant System Vents, was added in re-sponse to NRC Generic Letter 83-37, "NUREG-0737 Technical Specifications," ,

dated November 1, 1983. Vith regards to NUREG-0737, Item II.B.1, " Reactor Coolant System Vents," Item II.B.1 required that at least one vent path be operable and closed at all times at each of the following locations: pres-surizer steam space and Reactor Coolant System high points. These vents are not designed to function automatically to mitigate a Design Basis Accident or Transient and, therefore, have no nuclear safety related fune-tion, except to form part of the Reactcr Coolant System boundary.

The Special Reports section of the TS in Administrative Controls Section 6.9.2 administrative 1y lists those Special Reports already referenced in their respective TS, in this case TS 3/4.3.3.3 - Seismic Instrumentation, and TS 3/4.3.3.4 - Meteorological Instrumentation. These hava no nuclear safety-related function.

EFFECTS ON SAFETY:

The proposed changes to the TS are administrative. They are consistent with approved NRC guidance for relocating TS and vill be discussed in detail below. Vith the exception of the required Special Reports of TS 6.9.2.b and TS 6.9.2.c, the above referenced TS and their Bases are being deleted from the Technical Specifications and relocated to the USAR. The Special Reports required by TS 6.9.2.b and 6.9.2.c are being deleted, but i they are not being relocated to the USAR. In addition, the Action state- ,

ment Special Report requirements for inoperable Seismic Instruments end I

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'Page 4 Meteorological Monitoring Instrument Channels vould not be retained in the relocated TS. Rather, the reporting criteria of 10 CFR Section 50.72 and  !

10 CFR Section 50.73 vill be evaluated and applied as necessary. The '

requirements for operation of the systems in question are not being chang-ed, therefore, there is no adverse effect on safety.

Technical Specifications 3/4.3.3.3, 3/4.3.3.4 and 3/4.4.11 and their Bases are proposed for relocation to Chapter 16 of the USAR because they do not meet the criteria for inclusion in Technical Specifications published by the NRC as the " Final Policy Statement on Technical Specifications Improve-ments for Nuclear Power Reactors."

The four criteria are:

1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reac-tor coolant pressure boundary.

2. A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a chal-lenge to the integrity of a fission product barrier.

3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

4. A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

TS 3/4.3.3.3 - Seismic Instrumentation: ,

An application of the NRC's Final Policy Statement criteria to Seismic Instrumentation follows:

i Criterion 1 Seismic Instrumentation is not installed instrumentation that is used to detect degradation of the reactor coolant pressure boundary. The Final Policy Statement explicitly identifies the Seismic Monitoring Instrumentation as an example of con-trols that are not required to be retained in the TS. Seismic Instrumentation does not meet Criterion 1 of the Final Policy Statement.

Criterion 2 Seismic Instrumentation is not a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity e

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of a fission product barrier. It is provided to promptly detect and determine the magnitude of a seismic event so that the effect on those plant features, important to safety, may be evaluated. Seismic Instrumentation does not meet criterion 2 of the Final Policy Statement.

Criterion 3 Seismic Instrumentation does not provide a function or actuate in order to mitigate the consequences of a Design Basis Acci-dent or Transient. Seismic Instrumentation does not meet Criterion 3 of the Final Policy Statement. ,

Criterion 4 The seismic instrumentation has not been shown to be signifi-cant to public health and safety by either operational exper-ience or Probabilistic Risk Assessment. Seismic Instrumenta-tion was not included in the scope of the DBNPS Probabilistic Risk Assessment (PRA) (i.e., the Individual Plant Examination (IPE)) and is not currently included in the ongoing development of the external events portion of the IPE process (i.e.,

IPEEE). Seismic Instrumentation does not meet Criterion 4 of the Final Policy Statement.

TS 3/4.3.3.4 - Meteorological Instrumentation:

An application of the NRC's Final Policy Statement criteria to Heteorologi-cal Instrumentation follows:

Criterion 1 Heteorological Instrumentation is not installed instrumentation that is used to detect degradation of the reactor coolant pressure boundary. It is used to assess the need for recom-mending protective measures-following an accident. Heteorolo-gical Instrumentation does not meet criterion 1 of the Final Policy Statement.

Criterion 2 Heteorological Instrumentation is not a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Meteorological Instru-mentation does not meet Criterion 2 of the Final Policy Statement.

Criterion 3 Heteorological Instrumentation does not provide a function or ,

actuate in order to mitigate the consequences of a Design Basis  !

Accident or Transient. Meteorological Instrumentation does not l meet criterion 3 of the Final Policy Statement.

Criterion 4 The Meteorological Instrumentation has not been shown to be significant to public health and safety by either operational experience or Probabilistic Risk Assessment. Meteorological Instrumentation was not included in the scope of the DBNPS Probabilistic Risk Assessment (i.e., the Individual Plant  :

Examination (IPE)) and is not currently included in the ongoing l

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'Fage 6 development of the external events portion of the IPE process (i.e., IPEEE). Meteorological Instrumentation does not meet Criterion 4 of the Final Policy Statement.

TS 3/4.4.11 - Reactor Coolant System Vents:

'An application'of the NRC's Final Policy Statement Criteria to Reactor Coolant System Vents follows:

Criterion 1 Reactor Coolant System Vents are not installed instrumentation that is used to detect degradation of the reactor coolant pressure boundary. Reactor Coolant System Vents do not meet criterion 1 of the Final Policy Statement.

Criterion 2 Reactor Coolant System (RCS) Vents are not a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. His-operation or failure of the two hot leg vent valves cannot cause a Loss of Coolant Accident (LOCA) because the two hot leg vent lines have restrictive orifices sized such that the flow rate cannot exceed the RCS makeup system capability. The vent path through valves RC 239A and RC200 on the pressurizer is also designed and sized such that an inadvertent opening could not cause the RCS to depressurize when all pressurizer heaters are energized.

The Pilot Operated Relief Valve (PORV) vent path's operating restriction aspect will continue to be controlled under TS 3/4.4.3, Safety Valves and Pilot Operated Relief Valve - Opera-ting, which vill be retained in the Operating License. The Technical Specification that prescribes the control and testing of the RCS vents is being relocated to Chapter 16 of the Up-dated Safety Analysis Report with no changes, and the valves vill continue to be operated and tested in the same manner as before. Therefore, the Reactor Coolant System Vents do not meet Criterion 2 of the Final Policy Statement.

Criterion 3 Reactor Coolant System Vents are not required to provide a function or actuate in order to mitigate the consequences of a Design Basis Accident or Transient. The RCS Vents are provided to vent noncondensible gases and steam from the RCS that could inhibit natural circulation core cooling following any event involving a loss of offsite power and requiring long term cool-ing, such as a Small Break LOCA (SBLOCA). Although available for use, the vents are not required to operate to mitigate any Design Basis Accident or Transient. As described in USAR Section 6.3.3.1.4, " Discussion of Noncondensible Gases," DBNPS design basis events do not generate sufficient noncondensible gases to block natural circulation. The DBNPS SBLOCA analyses have taken credit for reflux cooling (coupled

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heat' transfer from-the RCS to the steam generator secondary side) to keep the reactor cool in the event of an interruption of natural circulation due to the accumulation of steam in the RCS. loop. Operation of the vents is not assumed in the USAR Chapter 15 safety analysis, as the vents are not part of the primary success path. Operation of the vents is an operator ,

action after an event has occurred and is utilized only if there is indication that natural circulation is'not occurring.

The Reactor Coolant System Vents do not meet Criterion 3 of the Final Policy Statement.

Criterion 4 The Reactor Coolant System Vents have not been shown to be significant to public health and safety by either operational experience or Probabilistic Risk Assessment. Results of the DBNPS PRA (i.e., the Individual Plant Examination (IPE)) in-dicate that the Reactor Coolant System Vents are not signi- l ficant in the mitigation of any Design _ Basis Accident. Reactor  ;

Coolant System Vents do not meet criterion 4 of the Final Policy Statement.

TS 6.9.2 - Special Reports:

The Special Reports listed in TS 6.9.2.b and TS 6.9.2.c are being deleted because the Seismic Monitoring Instrumentation and the Meteorological Monitoring Instrumentation vill no longer be part of the Operating License TS. Therefore, this is an administrative change and there vill be no adverse effect on safety.

Conclusions Relocation of TS 3/4.3.3.3, TS 3/4.3.3.4, and TS 3/4.4.11 to the USAR will not impact their systems' capabilities. The proposed TS changes vill maintain similar operation, maintenance, testing and system operability controls for the systems. Furthermore, any future changes to these systems  ;

and relocated TS will be evaluated as required by 10 CFR Section 50.59.-  !

l The proposed changes are administrative and consistent with guidance from i the NRC. These changes do not meet any criteria under the NRC's Final Statement on Technical Specification Improvements and, therefore, qualify for relocation to the USAR. The NRC has previously approved TS relocations under this policy, e.g., Amendment No. 122 to Facility Operating License No. NPF-12, Virgil C. Summer Nuclear Station, dated February 15, 1995, (TAC ]

Number M90765). There is no adverse effect on safety as a result of these l changes.

l SIGNIFICANT HAZARDS CONSIDERATION:

The Nuclear Regulatory Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazard exists due to a proposed amendment to an Operating License for a facility. A proposed amendment involves no significant hazards consideration if operation of the facility i

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in accordance with the proposed changes vould: (1) Not involve a signifi-cant increase in the probability or consequences of an accident previously evaluated; (2) Not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Not involve a significant reduction in a margin of safety. Toledo Edison has reviewed ,

the proposed changes and determined that a significant hazards considera-  !

tion does not exist because operation of the Davis-Besse Nuclear Power ,

Station, Unit Number 1, in accordance with these changes would-l la. Not involve a significant increase in the probability of an accident previously evaluated because no change is being made to any accident initiator. No previous analyzed accident scenario is changed, and initiating conditions and assumptions remain as previously analyzed. i The proposed changes are deletions and relocations of specifications that do not meet the NRC Final Policy Statement criteria for inclusion in Technical Specifications (TS). Furthermore, these relocations and deletions are consistent with the NRC guidance for TS provided by the

" Improved Standard Technical Specifications for Babcock and Wilcox ,

Plants," NUREG-1430, Revision 0. Therefore, it can be concluded that  !

the proposed changes do not involve a significant increase in the probability of an accident previously evaluated. L lb. Not involve a significant increase in the consequences of an accident previously evaluated because the proposed changes do not affect accident conditions or assumptions used in evaluating the radiological consequences of an accident. The proposed changes do not alter the.

source term, containment isolation or allovable radiological releases. .

2. Not create the possibility of a new or different kind of accident from any accident previously evaluated because the proposed changes do not change the way the plant is operated, and no new or different failure modes have been defined for any plant system or component important to safety, nor has any limiting single failure been identified as a result of the proposed changes. No new or different types of failures  ;

or accident initiators are introduced by the proposed changes.  ;

3. Not involve a significant reduction in a margin of safety because Seismic Instrumentation, Heteorological Instrumentation, and Reactor i Coolant System Vents are not inputs in the calculation of any safety ]

margin with regard to Technical Specification Safety Limits, Limiting Safety System Settings, other Technical Specification Limiting Conditions for Operation, or other previously defined margins for any structure, system, or component important-to safety.

CONCLUSION:

On the basis of the above, Toledo Edison has determined that the License Amend-ment Request does not involve a significant hazards consideration. As this ,

License Amendment Request concerns a proposed change to the Technical Specifica- i tions that must be reviewed by the Nuclear Regulatory Commission, this License Amendment Request does not constitute an unreviewed safety question.

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ATTACHMENT:

Attached are the proposed marked-up changes to the Operating License.

REFERENCES:

1. Technical Specifications 3/4.3.3.3 - Seismic Instrumentation, 3/4.3.3.4

- Meteorological Instrumentation, and 3/4.4.11 - Reactor Coolant System Vents and their Bases. Technical Specification 6.9.2 - Special Reports. ,

2. The NRC " Final Policy Statement on Technical Specifications Improve-ments for Nuclear Power Reactors", (58 FR 39132, dated July 22, 1993).

3. " Improved Standard Technical Specifications for Babcock and Vilcox Plants," NUREG-1430, Revision 0, dated September 28, 1992.  !

4. USAR Section 3.7.4, " Criteria for Seismic Instrumentatien Program."

5. USAR Section 2.3.3, "On-Site Meteorological Measurement Program."

6. USAR Section 5.5.10.2, " Description."

7. USAR Section 6.3.3.1.4, " Discussion of Noncondensible Gases"

8. Amendment No. 122 to Facility Operating License No. NPF-12, Virgil C.

Summer Nuclear Station, dated February 15, 1995 (TAC Number 90765). '

9. 10 CFR 50.36, " Technical Specifications."

10. 10 CFR 50.59, " Changes, Tests and Experiments."

11. 10 CFR 50.72, "Immediate Notification Requirements for Operating ,

Nuclear Reactors." j

12. 10 CFR 50.73, " Licensee Event Report System."

13. Generic Letter 83-37, "NUREG-0737 Technical Specifications." ,

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