ML20151Q763
| ML20151Q763 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/28/1988 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | |
| Shared Package | |
| ML20151Q751 | List: |
| References | |
| NUDOCS 8808110280 | |
| Download: ML20151Q763 (13) | |
Text
-
. . Dock 5t No. 50-346 Lictnsa No. NPF-3 Serial No. 1524 Enclosure Page 1 APPLICATION FOR AMENDMENT TO FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POVER STATION UNIT NO. 1 Attached are requested changes 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 changes (submitted under cover letter Serial No. 1524) concern:
Technical Speelfication 3/4.1.2.6, Boric Acid Pumps - Shutdovn; and Technical Specification 3/4.1.2.7, Boric Acid Pumps - Operating.
By: WD D. C. Shelton, Vice President, Nuclear
'l Svorn and subscribed before me this 28 th day of July, 1988.
( / O LN_
NotarfPublic,StateofOhio LAURIE A. HINKLE Hotwy Public. State al Ohle My ConsMon Enkes May 15.1991 8808110280 880728 PDR ADOCK 05000346 P PDC
,; Docks'tNo.50-346 Lictnsa No. NPF-3 1 Serial No. 1524 i L
Enclosure l Page 2 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 Specifications.
A. Time Required to Implement: This change vill be implemented within 45 days following NRC issuance of the License Amendment.
B. Reason for Change (FCR No. 86-0427): Delete Surveillance Requirement 4.0.5, Inservice Inspection and Testing of ASHE Code Class 1, 2 and 3 components, from the boric acid pumps Technical Specifications. ,
C. Safety Evaluation: See attached Safety Evaluation (Attachment No. 1).
D. Significant Hazards Consideration: See attached Significant Hazards Consideration (Attachment No. 2).
l l
l l
1
' . , Docke,t No. 50-346
, . . License No. NPF-3 Serial No. 1524 Attachment 1 Page 1 SAFETY EVALUATION INTRODUCTION The purpose of this Safety Evaluation is to review a proposed change to the Davis-Besse Nuclear Power Station, Unit No. 1, Operating License, Appendix A Technical Specifications. The proposed change involves deleting the references to Surveillance Requirement 4.0.5 from Technical Specification 3/4.1.2.7, Boric Acid Pumps - Operating, and 3/4.1.2.6, Boric Acid Pumps -
Shutdown. Because the boric acid pumps are part of the Chemical Addition System, and the Chemical Addition System is not required to function during an emergency condition, the boric acid pumps should not be required to be tested in accordance with Surveillance Requirement 4.0.5.
Technical Specification Surveillance Requirements 4.1.2.7 and 4.1.2.6 require at least one boric acid pump to be demonstrated operable, at least once per 31 days, by: a. Starting the pump; b. Verifying the pump's discharge pressure;
- c. Verifying pump operation; and d. Verifying the pump is aligned to receive electrical oover from an operable essential bus. In addition, both 4.1.2.7 and 4.1.2.6 require the boric acid pumps be tested in accordance with Surveillance Requirement 4.0.5.
Technical Specification 4.0.5 outlines Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2 and 3 components. Surveillance Requirement 4.0.5.a.2 requires "inservice inspection of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g)(6)(1)".
10 CFR 50.55a(g) outlines inservice inspection requirements and requires that components which are classified as ASME Code Class 1 and Class 2 be designed, and provided with access, to enable the performance of (i) inservice examination of such components (including supports) and (ii) tests for operational readiness of pumps and valves. Paragraph 10 CFR 50.55(g)(4) requires that throughout the service life, components (including supports) :
which are classified as ASME Code Class 1, 2 and 3 meet the requirements set ;
forth in the applicable Section XI editions and Addenda of the ASME Boiler and Vessel Code to the extent practical within the limitations of design, geometry and materials of construction of the components. Sub-paragraphs 10 CFR 50.55a(g)(4)(i) and (ii) require that operational testing prescribed in Section XI of the ASME Code include pumps and valves whose function is required for safety. l 1
Section XI of the ASME Boiler and Vessel Code provides the rules for inservice inspection of nuclear power plant components. Article IVA-1000, Scope and Responsibility, categorizes the areas subject to inspection and defines responsibilities, provisions for accessibility, examination methods, etc... Sub-paragraph IVA-1300 requires Class 1, 2 and 3 pressure-retaining components to meet the inspection requirements of Section XI of the ASME Boiler and Pressure Vessel Code.
+-s--ee- -, - , - . -,m f-m p3 -e.-g---$-r*p---#--. -y
I~ . Dockst No. 50-346
. Licanse No. NPF-3 !
Serial No. 1524 l Attachment 1 Page 2 The boric acid pumps are part of the Chemical Addition System and were originally designed to Class 3 requirements. However, the system was downgraded as part of the inservice inspection and testing program because they were non-0, non-seismic, not required to function during an emergency condition and not required for safety (i.e. not required to mitigate the consequences of an accident, shutdown the reactor or maintain the reactor in a shutdovn condition). As described in the Davis-Besse Updated Safety Analysis Report (USAR), the Chemical Addition System is not required to function during an emergency condition.
Redundant boric acid pumps and boric acid addition lines are provided to guard against a single component failure rendering the system inoperable. Boric acid is available from the two boric acid addition tanks as well as from the concentrate storage tank. The High Pressure Injection (HPI) pumps, taking suction from the Borated Vater Storage Tank (BVST), is the safety grade system for boron addition if the Chemical Addition System is inoperable. The Chemical Addition System malfunction analysis, as described in USAR Section 9.3.6.2.2, concludes that there are no safety-related functions which would be adversely affected by failures in the Chemical Addition System. Therefore, the boric acid pumps are not required to be tested in accordance with 10 CFR 50.55a(g),Section XI of the ASME Boiler and Pressure Vessel Code, and should not be required to be tested pursuant to Surveillance Requirement 4.0.5.
Accordingly, this License Amendment Request proposes deleting the reference to Surveillance Requirement 4.0.5 from Technical Specifications 4.1.2.7 and 4.1.2.6. The other Surveillance Requirements of 4.1.2.7 and 4.1.2.6 vill still require the pump to be tested to ensure it has not degraded.
This application also requests:
Revising the incorrect reference to Section 55.55a(g)(6)(1) in Surveillance Requirement 4.0.5. The correct reference is 50.55a(g)(6)(1);
Revising the title of Technical Specification 3/4.1.2.7 by adding an "s" to pump to make both the operating and shutdown Technical Specifications consistent, Boric Acid Pumps. The index is also being revised to show this change; and Revising the wording in Surveillance Requirement 4.1.2.6 by changing "the above required" to "one" to make both the operating and shutdown Technical Specification Surveillance Requirements consistent.
DOCUMENTS AFFECTED Davis-Besse Nuclear Power Station, Unit No. 1, Operating License, Appendix A.
Technical Specifications 3/4.1.2.7, Boric Acid Pumps - Operating, and 3/4.1.2.6, Boric Acid Pumps - Shutdown. ,
l ST 5011.04 (EN-SP-03003), Boric Injection Flovpath Boric Acid Pump Test.
I l
Docket No. 50-346
. , License No. NPF-3 Sarial No. 1524 Attachment 1 Page 3 REFERENCES Title 10 Code of Federal Regulations, Part 50.55a(g), Inservice Inspection Requirements.
Section XI of the ASME Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components.
Davis-Besse Nuclear Power Station, Unit No. 1, Updated Safety Analysis Report (USAR), Section 1.2.8.2, 1.2.8.3, 6.3.3.2.4, 9.3.6.2 and 9.3.6.3.
Safety Evaluation by the Office of Nuclear Reactor Regulation related to the revised Inservice Inspection and Testing Program, dated May 18, 1984 (Log No. 1521).
Davis-Besse Nuclear Power Station, Unit No. 1, Operating License, Technical Specification Basis Section 3/4.1.2, Boration Systems.
FUNCTIONS OF AFFECTED SYSTEMS Chemical addition operations are required to alter the concentration of various chemicals in the reactor coolant and auxiliary systems. The s 'em is designed to add boric acid to the Reactor Coolant System (RCS) for reat .vity control, lithium hydroxide for pH control, and hydrazine for oxygen control.
Two centrifugal boric acid pumps are provided to facilitate transfer of the concentrated boric acid solution from the boric acid addition tanks to the BVST, make-up tank, or the spent fuel storage pool. The pumps are sized so that when both are operating, one complete charge of concentrated boric acid solution from the boric acid addition tanks may be injected into the RCS in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The Chemical Addition System is not required to function during an emergency condition. Redundant boric acid pumps and boric acid addition lines are provided to guard against a single component failure rendering the system inadequate. Boric acid is available from the two boric acid addition tanks as well as from the concentrate storage tank. As discussed in Technical Specification Basis Section 3/4.1.2, Boration Systems, the boric acid pumps do provide a redundant means to ensure that negative reactivity control is available during each mode of operation. However, the HPI pumps, taking suction from the BVST, is the safety grade system for boron addition if the Chemical Addition System is inoperable.
EFFECTS ON SAFETY 10 CFR 50.55a(g) outlines the inservice inspection requirements for components whose function is required for safety. Similarly,Section XI of the ASME Boiler and Vessel Pressure Code outlines the inservice inspection requirements for Class 1, 2 and 3 components.
, Docket No. 50-346
. . License No. NPF-3 Sarial No. 1524 Attachment 1 l Page 4 As described in the USAR, the Chemical Addition System is not required to function during an emergency condition. USAR Section 9.3.6.3.1 also states that "the concentrated boric acid handled by this system can be maintained above its crystallization temperature by any one of at least two independent, full capacity heating systems, except when it is in the boric acid mix tank.
Even if boric acid solidification did make the system inoperable, the reactor can still be shutdown safely. In such a situation, sufficient boron could be added to the primary system by compensating for the temperature contraction of the reactor coolant with water, via the high pressure injection pumps, from the borated vater storage tank".
The Technical Specification surveillances, without the reference to j Surveillance Requirement 4.0.5, vill verify boric acid pump performance by l starting the pump, verifying the pump develops at least 93 percent of the discharge pressure for the applicable flow rate, veritying pump operation, and verifying the pump is aligned to receive electrical power from an operable essential bus.
As this is plant specific, the wording is different from the B&V Standard Technical Specifications. However, the proposed change is acceptable because it is a plant specific design consideration due to the Chemical Addition System not being required to function during an emergency condition and the HPI pumps, taking suction from the BVST, being the safety grade system for boron addition if the Chemical Addition System is inoperable.
PROPOSED AMENDMENT REQUEST DISCUSSION The propr,ed change involves deleting the reference to Surveillance Requirew.it 4.0.5 from Technical Specification 3/4.1.2.7, Boric Acid Pumps -
Opcrating, and 3/4.1.2.6, Boric Acid Pumps - Shutdown because testing in accordance with ASME Section XI requirements is not necessary. Therefore implementation of these changes vould:
Not increase the probability of occurrence of an accident previously evaluated in the USAR because the boric acid pumps, as part of the Chemical Addition System, are not required to function during an emergency condition.
Therefore, the boric acid pumps are not required to be tested in accordance with 10 CFR 50.55a(g) or Section XI of the ASME Boiler and Pressure Vessel Code and should not be required to be tested in accordance with Surveillance Requirement 4.0.5. The Technical Specification surveillances, without the I
reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded (10CFR50.59(a)(2)(i)).
Not increase the consequences of an accident previously evaluated in the USAR because the boric acid pumps, as part of the Chemical Addition System, are not l required to function during an emergency condition. Therefore, the boric acid
! pumps are not required to be tested in accordance with 10CFR50.55a(g) or Section XI of the ASME Boiler and Pressure Vessel code and should not be required to be tested in accordance with Surveillance Requirement 4.0.5. The Technical Specification surveillances, without the reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded (10CFR50.59(a)(2)(i)).
, Docket No. 50-346 l . License No. NPF-3 Serial No. 1524 Attachment i l Page 5 )
Not increase the probability of occurrence of a malfunction of equipment l important to safety previously evaluated in the USAR because the boric acid pumps, as part of the Chemical Addition System, are not required to function during an emergency condition. Therefore, the boric acid pumps are not required to be tested in accordance with 10 CFR 50.55a(g) or Section XI of the ASME Boiler and Pressure Vessel Code and should not be required to be tested in accordance with Surveillance Requirement 4.0.5. The Technical Specification surveillances, without the reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded.
The HPI pumps, taking suction from the BVST, is the safety grade system for boron addition if the Chemical Addition System is inoperable (10CFR50.59(a)(2)(1)).
Not increase the consequences of a malfunction of equipment important to safety previously evaluated in the USAR because the boric acid pumps, as part of the Chemical Addition System, are not required to function during an emergency condition. Therefore, the boric acid pumps are not required to be tested in accordance with 10 CFR 50.55a(g) or Section XI of the ASME Boiler and Pressure Vessel Code and should not be required to be tested in accordance with Surveillance Requirement 4.0.5. The Technical Specification surveillances, without the reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded.' The HPI pumps, taking suction from the BVST, is the safety grade system for boron addition if the Chemical Addition System is inoperable (10CFR50.59(a)(2)(1)).
Not create the possibility for an accident of a different type than any evaluated previously in the USAR because the boric acid pumps as part of the Chemical Addition System, are not required to function during an emergency condition. Therefore, the boric acid pumps are not required to be tested in accordance with Surveillance Requirement 4.0.5. The Technical Specification surveillances, without the reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded. The HPI pumps, taking suction from the BVST, is the safety grade system for boron addition if the Chemical Addition System is inoperable (10CFR50.59(a)(2)(ii)).
Not create the possibility for a malfunction of a different type than any evaluated previously in the USAR because the boric acid pumps, as part of the !
Chemical Addition System, are not required to function during an emergency condition. Therefore, the boric acid pumps are not required to be tested in accordance with 10 CFR 50.55a(g) or Section XI of the ASME Boiler and Pressure Vessel Code and should not be required to be tested in accordance with Surveillance Requirement 4.0.5. The Technical Specification surveillances, without the reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded. The HPI pumps, taking suction from the BVST, is the safety grade system for boron addition if the J Chemical Addition System is inoperable (10CFR50.59(a)(2)(ii)).
Not reduce the margin of safety as defined in the basis for any Technical Specification because the boric acid pumps, as part of the Chemical Addition System, are not required to function during an emergency condition.
I
. Docket No. 50-346 l
Licsnsa No. NPF-3 Ssrial No. 1524 -2 l Attachment 1
! Page 6 l
Therefore, the boric acid pumps are not required to be tested in accordance with Surveillance Requirement 4.0.5. The Technical Specification surveillances, without the reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded. The HPI pumps, taking suction from the BWST, is the safety grade system for boron addition if the Chemical Addition System is inoperable (10CFR50.59(a)(2)(iii)).
CONCLUSION P
Therefore, it is concluded that the proposed Technical Specification change does not create any unrevieved safety questions.
1
Docket No. 50-346
' . ' Licensa No. NPF-3
. Serial No. 1524 Attachment 2 Page 1 SIGNIFICANT HAZARDS CONSIDERATION INTRODUCTION The purpose of this License Amendment Request is to review a proposed change to the Davis-Besse Nuclear Power Station, Unit No. 1, Operating License, Appendix A Technical Specifications. The proposed change involves deleting the references to Surveillance Requirement 4.0.5 from Technical Specification 3/4.1.2.7, Boric Acid Pumps - Operating, and 3/4.1.2.6, Boric Acid Pumps -
Shutdown. Because the boric acid pumps are part of the Chemical Addition System, and the Chemical Addition System is not required to function during an emergency condition, the boric acid pumps should not be required to be tested in accordance with Surveillance Requirement 4.0.5.
Technical Specification Surveillance Requirements 4.1.2.7 and 4.1.2.6 require at least one boric acid pump to be demonstrated operable, at least once per 31 days, by: a. Starting the pumps b. Verifying the pump's discharge pressures e Verifying pump operations and d. Verifying the pump is aligned to receive electrical power from an operable essential bus. In addition, both 4.1.2.7 and 4.1.2.6 require the boric acid pumps be tested in accordance with Surveillance Requirement 4.0.5.
Technical Specification 4.0.5 outlines Surveillance Requirements for inservice inspection and testing of ASHE Code Class 1, 7 and 3 components. Surveillance Requirement 4.0.5.a.2 requires "inservice inspection of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g)(6)(1)".
10 CFR 50.55a(g) outlines inservice inspection requirements and requires that components which are classified as ASME Code Class 1 and Class 2 be designed, and provided with access, to enable the performance of (1) inservice examination of such components (including supports) and (11) tests for operational readiness of pumps and valves. Paragraph 10 CFR 50.55(g)(4) ,
requires that throughout the service life, components (including supports) which are classified as ASME Code Class 1, 2 and 3 meet the requirements set I forth in the applicable Section XI editions and Addenda of the ASHE Boiler and j Vessel Code to the extent practical within the limitations of design, geometry ,
and materials of construction of the components. Sub-paragraphs 10 CFR l 50.55a(g)(4)(1) and (ii) require that operational testing prescribed in Section XI of the ASME Code include pumps and valves whose function is required for safety.
Section XI of the ASHE Boller and Vessel Code provides the rules for inservice inspection of nuclear power plant components. Article IVA-1000, Scope and Responsibility, categorizes the areas subject to inspection and defines responsibilities, provisions for accessibility, examination methods, etc... Sub-paragraph IVA-1300 requires Class 1, 2 and 3 pressure-retalning j components to meet the inspection requirements of Section XI of the ASHE 1 Boiler and Pressure Vessel Code.
l r
I l
.w_ _ _ _ _ - . . - __r-, ., ,, .-r,, - _ , _ _ .,,-__m .,. , , , . , _ , , , _ - . _ , ,_g,, ,,.m,~,y, ,,-,,__.,m,,,,-.,_o., .m.,-.= , . , , _, _ , . . ,,,g-
Docket No. 50-346
'. Lictnsa No. NPF-3
. Sirial No. 1524 Attachment 2 Page 2 The boric acid pumps are part of the Chemical Addition System and were originally designed to Class 3 requirements. However, the system m downgraded as part of the inservice inspection and testing program because they were non-0, non-seismic, not required to function during an emergency i condition and not required for safety (i.e. not required to mitigate the consequences of an accident, shutdown the reactor or maintain the reactor in a shutdown condition). As described in the Davis-Besse Updated Safety Analysis Report (USAR), the Chemical Addition System is not required to function during an emergency condition.
Redundant boric acid pumps and boric acid addition lines are provided to guard against a single component failure rendering the system inoperable. Boric acid is available from the two boric acid addition tanks as well as from the concentrate storage tank. The High Pressure Injection (HPI) pumps, taking suction from the Borated Vater Storage Tank (BVST), is the safety grade system for boron addition if the Chemical Addition System is inoperable. The Chemical Addition System malfunction analysis, as described in USAR Section 9.3.6.2.2, concludes that there are no safety-related functions which would be adversely affected by failures in the Chemical Addition System. Therefore, the boric acid pumps are not required to be tested in accordance with 10 CFR 50.55a(g),Section XI of the ASME Boiler and Pressure Vessel Code, and should not be required to be tested pursuant to Surveillance Requirement 4.0.5.
Accordingly, this License Amendment Request proposes deleting the reference to Surveillance Requirement 4.0.5 from Technical Specifications 4.1.2.7 and 4.1.2.6. The other Surveillance Requirements of 4.1.2.7 and 4.1.2.6 vill still require the pump to be tested to ensure it has not degraded.
This application also requests:
Revising the incorrect reference to Section 55.55a(g)(6)(1) in Surveillance Requirement 4.0.5. The correct reference is 50.55a(g)(6)(1);
Revising the title of Technical Specification 3/4.1.2.7 by adding an "s" to pump to make both the operating and shutdown Technical Specifications consistent, Boric Acid Pumps. The index is also being revised to shov this change; and Revising the vording in Surveillance Requirement 4.1.2.6 by changing "the above required" to "one" to make both the operating and shutdown Technical Specification Surveillance Requirements consistent.
DOCUMENTS AFFECTED Davis-Besse Nuclear Power Station, Unit No. 1, Operating License, Appendix A.
Technical Specifications 3/4.1.2.7, Boric Acid Pumps - Operating, and 3/4.1.2.6, Boric Acid Pumps - Shutdown.
ST 5011.04 (EN-SP-03003), Boric Injection Flovpath Boric Acid Pump Test.
, Dockst No. 50-346
. Licsnsa No. NPF-3 Sarial No. 1524 Attachment 2 Page 3 REFERENCES Title 10 Code of Federal Regulations, Part 50.55a(g), Inservice Inspection Requirements.
Section XI of the ASME Boiler and Pressure Vessel Code, Rules for Inservice Inspection of Nuclear Power Plant Components.
Davis-Besse Nuclear Power Station, Unit No. 1, Updated Safety Analysis Report (USAR), Section 1.2.8.2, 1.2.8.3, 6.3.3.2.4, 9.3.6.2 and 9.3.6.3.
Safety Evaluation by the Office of Nuclear Reactor Regulation related to the revised Inservice Inspection and Testing Program, dated May 18, 1984 (Log No. 1521).
Davis-Besse Nuclear Power Station, Unit No. 1, Operating License, Technical Specification Basis Section 3/4.1.2, Boration Systems.
FUNCTIONS OF AFFECTED SYSTEMS Chemical addition operations are required to alter the concentration of various chemicals in the reactor coolant and auxiliary systems. The system is designed to add boric acid to the Reactor Coolant System (RCS) for reactivity control, lithium hydroxide for pH control, and hydrazine for oxygen control.
Two centrifugal boric acid pumps are provided to facilitate transfer of the concentrated boric acid solution from the boric acid addition tanks to the BVST, make-up tank, or the spent fuel storage pool. The pumps are sized so that when both are operating, one complete charge of concentrated boric acid solution from the boric acid addition tanks may be injected into the RCS in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The Chemical Addition System is not required to function during an emergency
- condition. Redundant boric acid pumps and boric acid addition lines are 4
provided to guard against a single component failure rendering the system inadequate. Boric acid is available from the two boric acid addition tanks as well as from the concentrate storage tank. As discussed in Technical Specification Basis Section 3/4.1.2, Boration Systems, the boric acid pumps do provide a redundant means to ensure that negative reactivity control is available during each mode of operation. However, the HPI pumps, taking suction from the BVST, is the safety grade system for boron addition if the Chemical Addition System is inoperable.
EFFECTS ON SAFETY 10 CFR 50.55a(g) outlines the inservice inspection requirements tor components whose function is required for safety. Similarly,Section XI of the ASl!E Boiler and Vessel Pressure Code outlines the inservice insper.tton requirements for class 1, 2 and 3 components.
l
_ _ . _ _ - __ _ . _ _ . _ _ . . . . ~ .,. _.
. Docket No. 50-346 Lic:nsa No. NPF-3 S2 rial No. 1524 l Attachment 2 Page 4 i
I l
As described in the USAR, the Chemical Addition System is not required to function during an emergency condition. USAR Section 9.3.6.3.1 also states that "the concentrated boric acid handled by this system can be maintained above its crystallization temperature by any one of at least two independent, full capacity heating systems, except when it is in the boric acid mix tank.
Even if boric acid solidification did make the system inoperable, the reactor can still be shutdown safely. In such a situation, sufficient boron could be added to the primary system by compensating for the temperature contraction of the reactor coolant with vater, via the high pressure injection pumps, from the borated water storage tank".
The Technical Specification surveillances, without the reference to Su veillance Requirement 4.0.5, vill verify boric acid pump performance by starting the pump, verifying the pump develops at least 93 percent of the discharge pressure for the applicable flow rate, verifying pump operation, and verifying the pump is aligned to receive electrical pover from an operable essential bus.
As this is plant specific, the wording is different from the B&V Standard Technical Specifications. However, the proposed change is acceptable because it is a plant specific design consideration due to the Chemical Addition System not being required to function during an emergency condition and the HPI pumps, taking suction from the BVST, being the safety grade system for boron addition if the Chemical Addition System is inoperable.
SIGNIFICANT HAZARDS CONSIDERATION The Commission has provided standards in 10CFR50.92(c) for determining whether a signJficant hazards consideration exists. A proposed amendment to an Operating License for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would:
(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 the margin of safety.
Toledo Edison has revieved the proposed changes and determined that a significant hazards consideration does not exist because the operation of the Davis-Besse Nuclear Power Station, Unit No. 1 in accordance with these changes vould:
Not involve a significant increase in the probability or consequences of an accident previously evaluated because the boric acid pumps, as part of the Chemical Addition System, are not required to function under an emergency condition. The HPI pumps, taking suction from the BVST, is the safety grade system for boron addition if the Chemical Addition System is inoperable.
Therefore, the boric acid pumps are not required to be tested in accordance with 10CFR50.55a(g) or Section XI of the ASHE Boller and Pressure Vessel Code and should not be required to be tested in accordance with Surveillance !
Requirement 4.0.5. The Technical Specification surveillance, without the 1 reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded (10CFh50.92(c)(1)).
l l
, Dockat No. 50-346
. Lictnse No. NPF-3 '
Ssrial No. 1524 )
Attachment 2 l Page 5 i l
l Not create the possibility of a new or different kind of accident from any accident previously evaluated because the boric acid pumps, as part of the Chemical Addition System, are not required to function under an emergency condition. The HPI pumps, taking suction from the BWST, is the safety grade system for boron addition if the Chemical Addition System is inoperable.
Therefore, the boric acid pumps are not required to be tested in accordance with 10CFR50.55a(g) or Section XI of the ASME Boiler and Pressure Vessel Code and should not be required to be tested in accordance with surveillance Requirement 4.0.5. The Technical Specification surveillance, without the reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded (10CFR50.92(c)(2)).
Not involve a significant reduction in a margin of safety because the boric acid pumps, as part of the Chemical Addition System, are not required to function under an emergency condition. The HPI pumps, taking suction from the BVST, is the safety grade system for boron addition if the Chemical Addition System is inoperable. Therefore, the boric acid pumps are not required to be tested in accordance with 10CFR50.55a(g) or Section XI of the ASHE Boiler and Pressure Vessel Code and should not be required to be tested in accordance with Surveillance Requirement 4.0.5. The Technical Specification surveillance, without the reference to Surveillance Requirement 4.0.5, vill still require the pump to be tested to ensure it has not degraded (10CFR50.92(c)(3)).
CONCLUSION
?
On the basis of the above, Toledo Edison has determined that the amendment request does not involve a significant hazards consideration.
_