ML20214J104

Application for Amend to License NPF-3,revising Tech Spec 3/4.7.7, Snubbers

ML20214J104
Person / Time
Site:	Davis Besse
Issue date:	03/12/1987
From:	Myers T, Williams J TOLEDO EDISON CO.
To:
Shared Package
ML20214J100	List: ML20214J098 ML20214J104 ML20214J108
References
TAC-65069, NUDOCS 8705270645
Download: ML20214J104 (8)

Text

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APPLICATION FOR AMENDMENT .

TO FACILITY OPERATING LICENSE NO. NPF-3 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Enclosed are the 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.1346) concern Section 3/4.7.7, Snubbers, Surveillance Requirement 4.7.7, Footnote 2 Section 3/4.7.7, Snubbers, Surveillance Requirement 4.7.7.le Section 3/4.7.7, Snubbers, Surveillance Requirement 4.7.7.2b, Footnote 63 Section 3/4.7.7, Snubbers, Surveillance Requirement 4.7.7.2c.28 Bases Section 3/4.7.7, Snubbers.

By Nd -

T.J./ypts Nuclear licensing Director For J. Williams, Jr.

Senior Vice President Nuclear Sworn to and subscribed before me this 12th day of March, 1987.

l.1&k

• M&

Notary Public, State of Ohio My cosmission expires /

8705270645 870519 DR ADOCK050g6

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Docket No. 50-346 License No. NPF-3 Serial No. 1346 Attachment The following information is provided to support issuance of the requested changen to the Davis-Besse Nuclear Power Station, Unit No. 1, Operating License NPF-3. Technical Specifications Sections 4.7.7 Footnote 2, 4.7.7.le, 4.7.7.2b Footnote 6 and 4.7.7.2e.2 and Bases Section 3/4.7.7, Snubbers.

A. Time Required to Implement:

This change is to be effective 30 days af ter issuance of the l License Amendment.

B. Reason for Change (Facility Change Request 86-0044 Revision C):

On January 30, 1985, Toledo Edison submitted to the NRC a License Amendment application (Serial No. 1113) to revise Technical Specification 3/4.7.7 Snubbers, in accorde.nce with '

Generic Letter 84-13. On April 24, 1986, Amendment No. 94 (Log l No. 1977) issued the requested changes to Technical Specification '

3/4.7.7. In conjunction with approval of this Amendment, Toledo Edison committed by letters dated January 22, 1986, (Serial No.

1239) and March 26, 1986, (Serial No. 1263) to submit a separate amendment request to include the two recommendatione outlined in the Amendment No. 94 NRC Safety Evaluation. The two recommenda-tions were to add a surveillance requirement which requires the performance of a post-transient inspection of all hydraulic and mechanical snubbers attached to sections of systems that have experienced an unexpected, potentially damaging transient and to add an acceptance criterion regarding functional testing i for snubber activation.

C. Safety Evaluations i See attached Safety Evaluation.

D. Significant llazards Consideration:

See attached Significant llazards Consideration.

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Dockst No. 50-346 License No. NPF-3 Serial No. 1346 Attachment 1 Page 1 l SAFETY EVALUATION i

l This safety evaluation addresses proposed revisions to the Davis-Besse l Nuclear Power Station Unit No.1 Operating License, Appendix A, Technical Specification 3/4.7.7, Snubbers. The safety function of all nuclear safety-related snubbers is to ensure that the integrity of nuclear safety-related systems is maintained during and following dynamic loads and to ensure that the snubber support system will not degrade normal system l

operation (i.e.. prevent thereal growth). The safety function of the Davis-Besse Nuclear Power Station Unit No. 1 Operating License. Appendix A. Technical Specifications, is to provide limiting technical conditions for plant operation and provide surveillance requirements to assure that the necessary quality of systems and components is maintained and that the ifmiting conditions of operation are met.

PROPOSED AMENDMENT REQUEST Davis-Besse Nuclear Power Station, Unit No. 1, Operating License, Appendix A. Technical Specifications NRC Ceneric Letter 84-13 Technical Specifications for Snubbers (Log No. 1508)

Amendment No. 94 to Facility Operating License No. NPT-33 Snubber Requirements; Safety Evaluation (Log No. 1977)

FCR 83-080, Revision D Serial No. 1263, dated March 26, 1986 Surveillance Requirement 4.7.7.le All safety-related snubbers are required to be operable in the applicable system mode to ensure that the structural integrity of the reactor cool-ant system and all other safety-related systems is maintained during and following a dynamic event. A dynamic event is a condition resulting from either a seismic event or a system transient event such as water hammer.

The proposed addition of Surveillance Requirement 4.7.7.le, Transient Event inspection, would specifically require that an inspection be per-formed of all hydraulic and mechanical snubbers attached to sections of nuclear nafety-related systems that have experienced unexpected, l

potentially damaging transients. Operational data would be reviewed to determine the systems or sections of systems potentially affected by the event which should be inspected. This inspection would be performed within six months following the transient event.

The inspection would consist of a visual inspection of hydraulic and mechanical snubbers and verification of freedom-of-motion of mechanical snubbers, Verification of freedom-of-motion of mechanical snubbers would be accomplished through the use of one of the following (1) manually induced snobbte movement s or (2) evaluation of in-place snubber piston settings or (3) stroking the mechanical snubber through its full range of travel.

Dockot No. 50-346 License No NPF-3 Serial No. 1346 Attachment 1 Page 2 1

The identification of an inoperable snubber through this inspection would place the plant in the action statement of the Limiting Condition for Operation 3.7.7 for snubbern .and the appropriate actions would then be e implemented. This change is consistent with the recommended addition of a Transient Event Inspection surveillance requirement as outlined in the l NRC's Safety Evaluation supporting Amendment No. 94 to the Davis-Besse l Operating License No. NPF-3.

Bases 3/4.7.7 l

l The addition of the Surveillance Requirement 4.7.7.le, Transient Event Inspection, would necessitate the revision of Bases 3/4.7.7, Snubbers.

The word " seismic" would be changed to " dynamic". This change would make the bases consistent with the intent of the surveillance requirement to test the snubbers after either a seismic event or system transient event.

Surveillance Requirement 4.7.7.2b, Footnote 6 Footnote 6 to Surveillance Requirement 4.7.7.2b states:

" Permanent or other exemptions from functional testing for individual st ubbers in these categories may be granted by the commission only if a justifiable basis for exemption is presented."

As this statement only reiterates the regulatory basis established in 10 CFR Part 50.12 for obtaining specific exemptions (in this case, exempt-ing individual safety-related snubbers from functional testing), it is not i

necessary that this footnote be included within the Technical Specific-ations. Deletion of Footnote 6 is an administrative change to the Techni-cal Specifications. This change is consistent with that proposed to the NRC (Serial No. 1263) in supporting the NRC's Safety Evaluation to Amendment No. 94 to the Davis-Besse Operating License No. NPF-3.

l Surveillance Requirement 4.7.7.2.c.2 The purpose of Surveillance Requirement 4.7.7.2c.2 for mechanical snubbers is to describe the acceptance criteria for in-place and bench testing. This surveillance requirement, as presently written, describes one acceptance criterion as the achieving of activation (i.e., restraining action) in both tension and compression. Ilowever, no limits for this required restraining action are provided by the acceptance criterion.

The addition of the words "within the specified range" to Surveillance Requirement 4.7.7.2c.2 would provide a limit for the acceptance criterion. This change is consistent with the Babcock and Wilcox Standard l Technical Specifications, NUREC-0103, Revision 4. This change is also l consistent with that proposed to the NRC (Serial No.1263) and accepted l in the NRC's Safety Evaluation supporting Amendment No. 94 to the Davis-l Besse Operating License No. NPF-3.

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I Dockot No. 50-346 License No. NPF-3 Serial No. 1346 Attachment 1 Page 3 Surveillance Requirement 4.7.7, Footnote 2 Footnote 2 to Su,rveillance Requirement 4.7.7 states that safety-related snubbers are listed in the latest revision of the applicabic surveillance test procedure (s). It further states that snubbers may be added to, or removed from, safety-related systems and their assigned groups "without prior Licensing Amendment". The proposed replacement of the word " prior" with the word "a" and " Licensing" with " License" clariffes that no license amendment is required either prior to, or following, such a change. This clarification is an administrative change.

DISCUSSION OF UNREVIEWED SAFETY QUESTIONS The proposed changes are administrative in nature or increase the surveillance requirements of the Davis-Besse Nuclear Power Station Unit No. 1. Implementation of these changes would not

1. Increase the probability of occurrence or the consequences of an accident or an1 function of equipment important to safety previously evaluated in the Safety Analysis Report (10CFR50.59(2)(i)) .

The proposed changes are either increasing the surveillance require-ments or are administrative and, therefore, do not. increase the probability or consequences of an accident previously evaluated.

2. Create the possibility for an accident or malfunction of a different type than any evaluated previously in the Safety Analysis Report (10CFR50.59(2) (ii)) .

The changes involve no accident or malfunction scenario. On matters related to nuclear safety, all accidents are bounded by previous analyses and no new accidents are involved.

3. Reduce the margin of safety as defined in the basis for any Technical Specification (10CFR50.59(2)(iii)).

The margin of safety is not reduced by these increased surveillance requirements and administrative changen.

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

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Docket No. 50-346 f License No. NPF-3 ,

i Serial No. 1346

Attachment 2 j Page 1 i

SIGNIFICANT 11AZARDS CONSIDERATION l

i The. proposed amendment request involves the following changes

! 1. Addition of a Surveillance Requirement 4.7.7.le, Transient Event

) Inspection, to require that an inspection be performed of all safety-l related hydraulic and mechanical snubbers attached to sections of l nystems that have experienced unexpected, potentially damaging trans-t lents. Revise Bases Section 3/4.7.7, Snubbers, to be consistent with

! this change.

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2. Deletion of an unnecessary footnote (Surveillance Requirement 4.7.7.2b, Footnote 6).

l 3. Addition of limits to the acceptance criteria for mechanical snubber l in-place and bench testing (Surveillance Requirement 4.7.7.2c.2).

4. Revision of the wording of Footnote 2 to Surveillance Requirement 4.7.7 to clarify the footnote.

The effects of these changes are detailed below Surveillance Requirement 4.7.7.le ,

j j All safety-related snubbers are required to be operable in the

] applicable system mode to ensure that the structural integrity of the i reactor coolant system and all other safety-related systems is maintained j during and following a dynamic event. A dynamic event is a condition l resulting from either a seismic event of a system transient event such as I water hammer. The proposed addition of Surveillance Requirement 4.7.7.le, t i Transient Event Inspection, would specifically require that an inspection

! be performed of all hydraulic and mechanical snubbers attached to sections

of nuclear safety-related systems that have experienced unexpected, potentially damaging transients. Operational data would be reviewed to

determine the systems or sections of systems potentially affected by the

) event which should be inspected. This inspection would be performed i within six months following the transient event.

l The inspection would consist of a visual inspection of hydraulic and mech-

] ancial snubbers and verification of freedom-of-motion of mechanical anubbers. Verification of freedom-of-motion of mechanical'enubbers would

, be accomplished through the use of one of the followingt (1) manually I induced snubber movement; or (2) evaluation of in-place snubber piston l settings or (3) stroking the mechanical snubber through its full range of j travel.

, The identification of an inoperable snubber through this inspection would i

place the plant in the action statement of the Limiting Condition for j operation 3.7.7 for snubbers, and the appropriate actions would then be 1

Dockot No. 50-346 License No. NPF-3 Serial No. 1346 Attachment 2 Page 2 i

implemented. This change is consistent with the recommended addition of a Transient Event Inspection surveillance requirement as outlined in the NRC's Safety Evaluation supporting Amendment No. 94 to the Davis-Besse Operating Licensing No. NPF-3.

Bases 3/4.7.7 t The addition of the Surveillance Requirement 4.7.7.le Transient Event Inspection, would necessitate the revision of Bases 3/4.7.7, Snubbers.

The word " seismic" would be changed to " dynamic". This change would make the bases consistent with the intent of the surveillance requirement to test the snubbers after either a seismic event or system transient event.

Surveillance Requirement 4.7.7.2b. Footnote 6 Footnote 6 to Surveillance Requirement 4.7.7.2b states:

" Permanent or other exemptions from functional testing for individual snubbers in these categories may be granted by the commission only if a justifiable basis for exemption is presented."

As this statement only reiterates the regulatory basis established in 10 CFR 50.12 for obtaining specific exemptions (in this case, exempting individual safety-related snubbers from functional testing), it is not necessary that this footnote he included within the Technical Specifica-tions. Deletion of Footnote 6 is an administrative change to the Techni-cal Specifications. This change is consistent with that proposed to the NRC (Serial No.1263) in supporting the NRC's Safety Evaluation to Amendment No. 94 to the Davis-Besse Operating License No. NPF-3.

Surveillance Requirement 4.7.7.2c.2 The purpose of Surveillance Requirement 4.7.7.2c.2 for mechanical snubbers is to describe the acceptance criteria for in-place and bench testing. This surveillance requirement, as presently written, describes an acceptance criterion as the achieving of activation (i.e., restraining action) in both tension and compression. Ilowever, no limits for this required restraining action are provided by the acceptance criterion.

The addition of the words "within the specified range" to Surveillance Requirement 4.7.7.2c.2 would provide a limit for the acceptance criterion. This change is consistent with the Babcock and Wilcox Standard Technical Specifications, NUREG-0103, Revision 4. This change is also consistent with that proposed to the NRC (Serial No.1263) and accepted in the NRC's Safety Evaluation supporting Amendment No. 94 to the Davis-Besse Operating License No. NPF-3.

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i Docket No. 50-346 License No. NPF-3 l Serial No. 1346 Attachment 2 Page 3 Surveillance Requirement 4.7.7, Footnote 2 I Footnote 2 to Surveillance Requirement 4.7.7 states that safety-related j snubbers are listed in the latest revision of the applicable surveillance i test procedure (s). It further states that snubbers may be added to, or

) removed from, safety-related systems and their assigned groups "without j prior Licensing Amendment". The proposed replacement of the word " prior" 4 with the word "a" and " Licensing" with the word " License" clariffes that i no license amendment is required either prior to, or following, such a j change. This clarification is an administrative change.

BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION i

l The proposed change does not involve a significant hazards consideration because operation of Davis-Besse Unit No. 1 in accordance with this change would not:

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

The proposed changes are either increasing the surveillance require-J ments or are administrative and, therefore, do not increase the I probability or consequences of an accident previously evaluated.

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

} It has been determined that a new or different kind of accident will

not be possible due to this change. These changes either increase  ;

l surveillance requirements or are administrative and do not create the

! possibility of a new or different kind of accident.

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

. The changes requested are either administrative or increase the i

surveillance requirements and, therefore, will not reduce the margin  !

l of safety.

On the basis of the above Toledo Edison has determined that the amendment I l request does not involve a significant hazards consideratica.

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