ML20077F120

Application for Amend to License NPF-3,revising TS SRs for Reactivity Control Sys

ML20077F120
Person / Time
Site:	Davis Besse
Issue date:	12/06/1994
From:	Stetz J CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20077F122	List: ML20077F120 ML20077F124
References
2249, NUDOCS 9412130272
Download: ML20077F120 (9)

Text

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WNTEN ENERGY 300 Modison Avenue John P. Stetr Toledo, OH 43652-0001 Vice President - Nuclear 419-249-2300 Davls Besse l

l Gocket Number 50-346 License Number NPF-3 1 Serial Number 2249 l l

l December 6, 1994 United States Muclear Regulatory Commission Document Control Desk Vashington, D. C. 20555

Subject:

License Amendment Application to Revise Various Technical Specification Surveillance Requirements for Reactivity -

Control Systems Gentlemen:

Enclosed is an application for an amendment to the Davis-Besse Nuclear ,

Power Station (DBNPS), Unit Number 1 Operating License Number NPF-3,  !

Appendix A, Technical Specifications. The proposed changes involve '

Technical Specification (TS) 4.0.5, Applicability, and its associated Bases; TS 3/4.1.2.3, Reactivity Control Systems - Makeup Pump - Shut- ,

down; TS 3/4.1.2.4, Reactivity Control Systems - Makeup Pumps - Opera-ting; TS 3/4.1.2.6, Reactivity Control Systems - Boric Acid Pump -

Shutdown; and TS 3/4.1.2.7, Reactivity Control System - Boric Acid Pumps - Operating.

The proposed changes would replace the specific monthly surveillance requirements associated with the makeup pumps and boric acid pumps with a surveillance requirement referencing TS 4.0.5, which, in turn, refer-encesSection XI of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code. Surveillance requirements associated with inservice testing in accordance with Section XI of the ASME Boiler and Pressure Vessel Code would continue to be performed on a quarterly basis. It is also proposed that TS 4.0.5 and its associated Bases be ,

revised pursuant to the NRC Staff's recommendation in NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, to remove the text regarding NRC approval of relief requests.

Toledo Edison requests that this amendment be issued by the NRC by June ,

1, 1995. , q 1oUcrat Operotmg Companies.

Clevotand Elecinc iliuminating 9412130'272 941206 i Toledc Edison PDR ADOCK 05000346 003 PDR P

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. Docket Number 50-346 License Number NPF-3 Serial Number 2249 Page 2 Should you have any questions or require additional information, please contact Mr. Villiam T. O'Connor, Manager - Regulatory Affairs, at (419) 249-2366.

Very truly yours, dk KAS/laj cc: L. L. Gundrum, DB-1 NRC/NRR Project Manager J. B. Martin, Regional Administrator, NRC Region III S. Stasek, DB-1 NRC Senior Resident Inspector J. R. Villiams, Chief of Staff, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)

Utility Radiological Safety Board i

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Docket Numbsr 50-346

. License Number NPF-3 Serial Number 2249 Enclosure Page 1 APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NPF-3 DAVIS-BESSE NUCLEAR POVER STATION UNIT NUMBER 1 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 2249) concern:

Appendix A, Technical Specification 4.0.5, Applicability, and Bases 4.0.5, Applicability Appendix A, Technical Specification 3/4.1.2.3, Reactivity Control Systems - Makeup Pump - Shutdown Appendix A, Technical Specification 3/4.1.2.4, Reactivity Control Systems - Makeup Pumps - Operating Appendix A, Technical Specification 3/4.1.2.6, Reactivity Control Systems - Boric Acid Pump - Shutdown Appendix A, Technical Specification 3/4.1.2.7, Reactivity Control Systems - Boric Acid Pumps - Operating By: k sh/f J. P.'Stetz,'Vic6 President - Nuclear Sworn and subscribed before me this 6th day of December, 1994.

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. A NotaryPflic, State of Ohio EVELYN L DRESS Notary Public. State of Ohio My Commission Egires 7/28/99

. Docket Number 50-346 License Number NPP-3 Serial Number 2249 Enclosure

. Page 2 The following information is provided to support issuance of the requested changes to Davis-Besse Nuclear Power Station, Unit Number 1 Operating License NPP-3, Appendix A, Technical Specification (TS) 4.0.5 and its associated Bases; TS 3/4.1.2.3, Reactivity Control Systems -

Makeup Pump - Shutdown; TS 3/4.1.2.4, Reactivity Control Systems -

Makeup Pumps - Operating; TS 3/4.1.2.6, Reactivity Control Systems -

Boric Acid Pump - Shutdown; and TS 3/4.1.2.7, Reactivity Control Systems - Boric Acid Pumps - Operating.

2 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 92-0014, Revision 0):

The proposed changes vould replace the specific monthly surveillance requirements for the makeup pumps and boric acid pumps with a surveillance requirement referencing TS 4.0.5 which, in turn, referencesSection XI of the American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code. Surveillance requirements associated with inservice testing in accordance with Section XI of the ASME Boiler and Pressure Vessel Code vould continue to be performed on a quarterly basis. These changes vould reduce the potential for pump degradation that can result from excessive testing. In addition, a cost savings would result from the reduction in this testing. '

Pursuant to the NRC Staff's recommendation in NUREG-1482, the proposed changes vould also remove wording in TS 4.0.5 and its associated Bases regarding NRC approval of relief requests.

C. Safety Assessment and Significant Hazards Consideration : See Attachment.

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, . Dockat Number 350-346 License Number NPF-3 Serial Number 2249 Attachment Page 1 SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 92-0014 TITLE Revision of Technical Specifications 4.0.5, Applicability, and its associated Bases; 3/4.1.2.3, Reactivity Control Systems - Makeup Pump

- Shutdown; 3/4.1.2.4, Reactivity Control Systems - Makeup Pumps -

Operating; 3/4.1.2.6, Reactivity Control Systems - Boric Acid Pump -

Shutdown; and 3/4.1.2.7, Reactivity Control Systems - Boric Acid Pumps

- Operating.

DESCRIPTION The purpose of the proposed changes is to modify the Davis-Besse Nuclear Power Station (DBNPS) Operating License NPF-3, Appendix A Technical Specifications (TS) Sections 3/4.1.2.3, Reactivity Control Systems - Makeup Pump - Shutdown; 3/4.1.2.4, Reactivity Control Systems - Makeup Pumps - Operating; 3/4.1.2.6, Reaci.ivity Control Systems - Boric Acid Pump - Shutdown; and 3/4.1.2.7, Reactivity Control Systems - Boric Acid Pumps - Operating.

The wording of each Surveillance Requirement (SR) associated with these four TS sections are similar. In addition to meeting the requirements of TS 4.0.5, the existing SRs require a monthly verification of pump performance, referencing a desired discharge pressure. It is proposed that each of these SRs be replaced with a new SR. The new SR vould state:

No additional Surveillance Requirements other than those required by Specification 4.0.5 are applicabl.e.

Technical Specification 4.0.5.a.2 states that inservice testing of American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of l

I the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g). Accordingly, inservice testing activities comply with ASME Boiler and Pressure Vessel Code,Section XI, 1986 Edition. The makeup pumps and boric acid pumps are presently tested on a quarterly basis in accordance with TS 4.0.5, in I addition to the monthly testing specified under the existing SRs. The l proposed changes vould eliminate the monthly testing requirements, l thereby reducing unnecessary pump operation which may lead to l degradation.

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Dockat Numbar 50-346 Licensa Numbar NPF-3 Sarial Nurbar 2249 At.tachment Page 2 These proposed changes would also bring the TS SRs in closer agreement with the lastest version of the Standard Technical Specifications for Babcock and Vilcox Pressurized Vater Reactors (NUREG-0103, Revision 4), which does not require monthly testing of the makeup pumps and boric acid pumps.

The proposed changes vould also modify TS 4.0.5, Applicability, and its Bases to remove the text regarding NRC approval of relief requests. This change is proposed pursuant to the NRC recommendation in NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, in Section 6.3. In addition, TS 4.0.5.a.1 is proposed for deletion since it is obsolete, and TS 4.0.5.a.2, as a result, is renumbered as TS 4.0.5.a.

SYSTEM, COMPONENTS AND ACTIVITIES AFFECTED Hakeup and Purification System /Hakeup Pumps Testing Chemical Addition System / Boric Acid Pumps Testing TS 4.0.5 and its associated Bases reference to 10CFR50.55a(g)  ;

SAFETY FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS AND ACTIVITIES The Hakeup and Purification System is described in Section 9.3.4 of ,

the DBNPS Updated Safety Analysis Report (USAR). The Makeup and  !

Purification System is designed to accommodate the following functions during normal reactor operations

a. To control the Reactor Coolant System (RCS) inventory during all phases of normal reactor operation l l

b. To receive, purify and recirculate reactor coolant water )

c. To maintain the required boron concentration in the RCS (to control reactivity)

d. To provide seal injection water for the four reactor coolant l pumps I

e. In conjunction with the pressurizer, accommodate changes in reactor coolant volume due to small temperature changes

f. To maintain the proper concentration of hydrogen and hydrazine for oxygen control, and lithium for pH control

g. Provide makeup to the RCS for protection against small breaks in the RCS pressure boundary

h. To degas the RCS

1. To add borated water to the Core Flooding Tanks In addition, the Makeup and Purification System provides feed and bleed capability to maintain core cooling in the event of a beyond design-basis loss of all secondary side cooling.

Dockst Nuzb r 50-346

.Liesnsa Numb 2r NPF-3 Sarial Numbar 2249 At.tachment Page 3 The makeup pumps are part of the Makeup and Purification System.

There are two makeup pumps, each capable of supplying the required reactor coolant pump seal and makeup flov. One is normally in operation while the other, kept on standby status, is used as needed.

The Chemical Addition System is described in Section 9.3.6 of the DBNPS USAR. Chemical addition operations are required to alter the concentration of various chemicals in the reactor coolant and auxiliary systems. The chemical addition system is designed to add boric acid to the reactor coolant system for reactivity control, lithium hydroxide for pH control, and hydrazine for oxygen control.

The system also provides boric acid for other station components, and is sized to be able to add sufficient boric acid to maintain the core 1% Ak/k subcritical at any time during life. The chemical addition system is not required to function during an emergency condition.

The boric acid pumps are part of the Chemical Addition System. There are two boric acid pumps provided to facilitate transfer of the concentrated boric acid solution from the boric acid addition tanks to the borated water storage tank, makeup tank, or the spent fuel storage pool.

The function of TS 4.0.5 is to incorporate into the Operating License the 10CFR50.55a requirements for inservice testing and inspection.

EFFECTS ON SAFETY The makeup pumps and boric acid pumps are presently tested quarterly per ASME Section XI criteria. The pumps are started from the control room for the tests (unless they are already running) and typically are run for longer than 15 minutes. The tests include differential pressure, inlet pressure, flow, and vibration parameters, and provide for a thorough ano detailed evaluation of pump performance.

The present Surveillance Requirements specify monthly pump runs to verify discharge pressure, and monthly verifications that the pumps are aligned to receive electrical power from operable essential buses.

The proposed changes vould result in the deletion of these monthly requirements. The monthly pump runs provide for a more frequent demonstration of one aspect of pump operability, however they increase the potential for excessive pump degradation. The monthly verification of electrical power alignment is not significant since each pump can only be aligned to a single essential power supply. The power supply must be aligned or else the pump cannot be run, and if the pump cannot be run, the associated surveillance requirement cannot be completed.

The removal of the wording from TS 4.0.5.a and its associated Bases regarding NRC approval of relief requests is consistent with the NRC Staff's recommendation in NUREG-1482. The revised TS 4.0.5.a vill thus reflect 10 CFR 50.55a, whereby relief requests need not be granted prior to implementation. The change to renumbering TS 4.0.5.a.1 and 2 is an accompanying editorial change.

Docket Number 50-346 )

Licensa Number NPF-3 Serial Number 2249 Attachment Page 4 Based on the above, the proposed changes vould have no adverse effect on plant safety.

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 l amendment involves no sign!ficant hazards consideration if operation of the facility in accordance with the proposed changes vould: (1)

Not involve a significant 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 consideration does not exist because operation of the Davis-Besse Nuclear Power Station Unit Number 1, in accordance with these changes vould la. Not involve a significant increase in the probability of an accident previously evaluated because no accident initiators, conditions or assumptions are affected by the proposed changes to replace the specific monthly surveillance requirements for the makeup and boric acid pumps with surveillance requirements referencing TS 4.0.5 (ASHE Boiler and Pressure Code Section XI

• requirements) and to delete wording regarding NRC approval of relief requests.

lb. Not involve a significant increase in the consequences of an accident previously evaluated because no accident conditions or assumptions are affected by the proposed changes to replace the specific monthly surveillance requirements for the makeup and boric acid pumps with surveillance requirements referencing TS 4.0.5 (ASHE Boiler and Pressure Code Section XI requirements),

and to delete wording regarding NRC approval of relief requests.

The proposed changes do not alter the source term, containment isolation, or allovable releases. The proposed changes, therefore, vill not increase the radiological consequences of a previously evaluated accident.

2a. Not create the possibility of a new kind of accident from any accident previously evaluated because no new accident initiators or assumptions are introduced by the proposed changes to replace the specific monthly surveillance requirements for the makeup and boric acid pumps with surveillance requirements referencing TS 4.0.5 (ASHE Boiler and Pressure Code Section XI requirements),

and to delete wording regarding NRC approval of relief requests.

The proposed changes do not alter any accident scenarios.

2b. Not create the possibility of a different kind of accident from any accident previously evaluated because the surveillance requirements for the makeup and boric acid pumps only affect the testing of existing components, systems, and functions and do

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Docket Number 50-346 License Number NPF-3 Serial Number 2249 Attachment Page 5 not introduce any new requirements that are not met with the existing testing of components, systems, and functions. These proposed changes and the deletion of wording regarding NRC approval of relief requests do not alter any accident scenarios.

3. Not involve a significant reduction in a margin of safety because the proposed changes to replace the specific monthly surveillance requirements for the makeup and boric acid pumps with.

surveillance. requirements referencing TS 4.0.5 (ASME Boiler and

-Pressure Code Section XI requirements), and to delete wording regarding NRC approval of relief requests do not reduce or adversely affect the capabilities of any plant structures, systems or components.

CONCLUSION On the basis of the above, Toledo Edison has determined that the License Amendment Request does not involve a significant hazards consideration. As this License Amendment Request concerns a proposed change to the. Technical Specifications that must be reviewed by the Nuclear Regulatory Commission, this License Amendment Request does not constitute an unreviewed safety question.

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

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