Text

Proposed Tech Specs Supporting Amend to License NPF-3 Re Leak Rate Requirement for Containment Purge & Exhaust Isolation Valves
	ML20076F393
Person / Time
Site:	Davis Besse
Issue date:	08/18/1983
From:	; TOLEDO EDISON CO.
To:	;
Shared Package
ML20076F348	List: ML20076F338; ML20076F360; ML20076F393;
References
	TAC-52417, TAC-53296, TAC-56794, NUDOCS 8308260029
	Download: ML20076F393 (40)
	v • d • e

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CONTAINMENT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) with soap bubbles while the containment is pressurized to P '

38 psig, during each Type A test. a

f. Air locks shall be tested and demonstrated OPERABLE per Surveillance Requirement 4.6.1.3.

g. Leak' age from isolation valves that are sealed with fluid from a seal system may be excluded, subject to the provisions of Appendix J,Section III.C.3, when determining the combined leakage rate provided the seal system and valves are pres-surized to at least 1.10 P 41.8 psig, and the seal system capacity is adequate to main,tain system pressure for at least 30 days.

h. Type B tests for penetrations employing a continuous leakage monitoring system shall be conducted at P , 38 psig, at intervals no greater than once per 3 year $.

1. All test leakage rates shall be calculated using observed data ' ~

converted to absolute values. Error analyses shall be performed .

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to select a balanced integrated leakage measurement system. i

[K d'. The provisions of Specification 4.0.2 are not applicable.

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DAVIS-BESSE, UNIT 1 3/4 6-4 8308260029 830818 PDR ADOCK 05000346 P PDR

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l Dockst No. 50-346 !

License No. NPF-3 Serial No. 979 August 18, 1983 ;

Attachment II I. Changes to Davis-Besse Nuclear Power Station Unit 1, Appendix A Technical Specifications A. Time required to Implement. This change is to be effective upon NRC approv'al.

B. Reason for Change (Facility Change Request 83-065).

All incore detector strings, rather than just the symmetrig incores are used for calculation of hot channel factors (Fj and j H

Fq ).

C. Safety Evaluation (See attached)

D. Significant Hazards Considerations (See attached) i I

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I SAFETY EVALUATION This amendment request proposes changes to Davis-Besse Technical Specifi-cation Section 3.3.3.2 relating to the incore detector instrumentation system. The function of the incore detector system is to represent the spatial neutron flux distribution and to provide input for nuclear physics parameter calculations.

The proposed change corrects an error in Technical Specification 3.3.3.2.

This section implies that only the symmetric incoge detector system is utilized for calculation of hot channel factors TH and F g. However, all strings in the incore detector system are used for these calcula-tions. The reference to symmetric incores for the hot channel factor calculation should therefore be corrected since the proposed change reflects the actual operating condition and since operability of at least 75% of the detectors used for this calculation will be required by the proposed change to the Technical Specifications.

Based on the above, it is concluded that this change in the Technical Specification does not present any unreviewed safety questions.

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I SIGNIFICANT HAZARD CONSIDERATION _

The amendment request to include operability of 75% of the incore detector strings, rather than just the ymmetric incores that are used for calcula-

" es n e n ain a significant tion of hot channel factors ( ^H "t a O misrepresentation in the Technical hazard. The request is to correc ,

1 Specifications that implies only the symmetric incore detgctor system is and F . 'Al1~

utilized strings inforthe the calculation incore I system areof theusedhot for channel factors Fa' factors the hot channel 9 and this request will reflect the actual operation.

The revised Technical Specification places additional restrictions on the actual total number of incore detectors that are rel1uired operable in each core quadrant.

The granting of the request would not:

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

The inclusion of operability of 75% of the inco,re detector string will not increase the probability of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident previously evaluated 10CFR50.92(C)(2). l All accidents are still bounded by previoits analysis and no ncy accidents are involved. ..

3) InvolveasignificantreductioninamargDiofsafety10CFL50.92(Cj(3),

This request will maintain the margir.s ascuvied'in the accident analysis. , \l

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Therefore, based on the attached safety evaluation and the abo,ve, the ,

requested amendment does not contain a Significant !!azard. .

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y 'fith less': nan :ne specified mini =um incere detector arrangeacn: 0~ERAELE, do notr use incore ce:ectors for the above applicacie measurement. The provisions of Specifications 3.0.3 and 3.0.4 are not a;:plicable.

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Serial No. 979'

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I. Changes to Davis-Besse Nuclear Power Station Unit 1, Appendix B

, Technical Specifications A. Time required to Implement. This change is to be effective upon

' NRC approval.

' B. Reason for Change (Facility Change Request 83-086).

In response to' a letter from Mr. J. Stolz, dated December 21, 1982 (Log No. 1163) concerning Application to Amend Appendix B Technical Specifications.

C. Safety Evaluation (See attached)

D. Significant. Hazards Consideration (See attache'd) 4 5

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h SAFETY EVALUATION This amendment request concerns deletion of Sections 2.0, 2.1, 2.2, 2.3, 3.1, 4.0 and 5.4.1 Part A of Appendix B Technical Specifications and ;

, . submittal of an Environmental Protection Plan.

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l The monitoring required by Sections 2.1, 2.2, 2.3, 2.1 and 4.0 of Appendix B

! consists of environmental impact assessments of the effect of plant operation on water chemistry, zooplankton, phytoplankton, benthos, migratory i

birds, vegetation, and noise levels. More specifically, these studies are a designed to assess the effect of the cooling tower, the non-radioactive portions of our waste water and the cooling water intake system on the wildlife around the plant. These environmental surveillance programs were developed "to monitor the non-radiological impacts from Davis-Besse. . ."

(Ap.B Sec. 3.1) and as such are non-nuclear related. In addition, these 4

programs require monitoring beyond that which is required in the NPDES Permit for Davis-Besse issued by the Ohio Environmental Protection Agency.

Since the time that the original Technical Specifications for Davis-Besse

, were issued, a legal decision was made by the Atomic Safety Licensing Appeal Board that has a direct impact upon the non-radiologic environmental

monitoring programs of all nuclear power plants. As a result of this 27 December 1978 (" Yellow Creek") decision, the NRC may no longer require any non-radiologic environmental monitoring beyond that which in required by the NPDES Permit. The Board determined that the 1972 amendments to the Federal Water Pollution Control Act vest primary responsibility for controlling water pollution in the EPA Administrator and prohibit other federal agencies from invoking the National Environmental Policy Act, under the guise of License conditions, as authority for imposing different

monitoring requirements than those in the NPDES Permit.

Discontinuance of the non-radiologic environmental monitoring does not affect the design or function of any operating systems or monitoring i equipment connected with nuclear safety.

Reporting requirements of the Proposed Environmental Protection Plan involve copying the NRC on routine reports sent to the EPA concerning non-conformance with and/or changes to the Station NPDES permit.

Furthermore, any unusual environmental occurrence and/or change to the site which might involve an environmental impact question shall be recorded and reported to the NRC within 5 days by. telephone, telegraph, or facsimile transmissions followed by a written report.

Based on the above, it is concluded that this change in the Technical Specification does not present any unreviewed safety questions.

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SIGNIFICANT HAZARD CONSIDERATION t

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The attached amendment request for a change to Appendix B of the Davis-Besse Nuclear Power Station Unit 1 Technical Specification does not contain a significant hazard. The request is being submitted in response to a NRC request to incorporate the non-radiological non-aquatic matters into a new Appendix B retitled as an Environmental Protection Plan (EPP).

The request for the EPP follows a proposed guidelines established by the NRC and modified to include revisions due to the " Yellow Creek Decision" and completion of monitoring as required by the Technical Specifications.

All radiological Environmental Technical Specifications in Appendix B a under current NRC practices are to be incorporated into Appendix A.

The EPP is designed to promote NRC awareness of environmental effects of

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plant operation while recognizing that regulation of non-radiological aquatic matters is the responsibility of other agencies. In accordance l with the proposed EPP unusual or important environmental events that

indicates or could result in significant environmental impact causally t

related to plant operation shall be reported and promptly reported to the NRC.

l The granting of the request would not:

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

This request will not increase the probability or consequences of an accident previously evaluated as the' radiological parts of Appendix B will be covered by Appendix A. The non-radiological non-aquatic matters will be governed by other agencies.

2) Create the possibility of a new or different kind of accident pre-

viously evaluated 10CFR50.92(C)(2).

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

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

This request will maintain the margins assumed in the accident analysis.

Therefore, based on the attached safety evaluation and the above, the requested amendment does not contain a Significant Hazard.

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l APPENDIX B, PART II, NON-RADIOLOGICAL j j

TO FACILITY OPERATING LICENSE N0. NPF-3

' DAVIS-BESSE NUCLEAR POWER STATION UNIT N0. 1 TOLED0 EDISON COMPANY DOCKET NO. 50-346 ENVIRONMENTAL PROTECTION PLAN (NON-RADIOLOGICAL)

July,1983

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DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 ENVIRONMENTAL PROTECTION PLAN

'(N0N-RADIOLOGICAL)

TABLE OF CONTENTS Section Page 1.0 Objectives of the Environmental Protection Plan. . . . . . . . . 1-1 s

2.0 Environmental Protection Issues. . . . . . . . . . . . . . . . . 2-1 2

3.0 Consistency Requirements . . . . . . . . . . , . . . . . . . . . 3-1 3.1 Plant Design and Operation . . . . . . . . . . . . . . . . . . . 3-1 3.2 Reporting Related to the NPDES Permits and State Certification . 3-2 3.3 Changes Required for Compliance with Other Environmental Regul a tion s . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3 4.0 Environmental Conditions . . . . . . . . . . . . . . . . . . . . 4-1 4.1 Unusual or Important Environmental Events. . . . . . . . . . . . 4-1 5.0 Administrative Procedures. . . . . . . . . . . . . . . . . . . . 5-1 5.1 Review and Audit . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.2 Records Retention. . . . . . . . . . . . . . . . . . . . . . . . 5-1 5.3 Changes in Environmental Protection Plan . . . . . . . . . . . . 5-2 4

5.4' Plant Reporting Requirements . . . . . . . . . . . . . . . . . . 5-2

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1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of environmental values during construction and operation of the nuclear facility.

The principal objectives of the EPP are as follows:

(1) Verify that the plant is operated in an environmentally acceptable manner, as estabilished by'the FES and other NRC environmental impact assessients. '

(2) Coordinate NRC requirements and maintain consistency with other Federal, State and local requirements for environmental protection.

(3) Keep NRC informed of the environmental effects of facility construction and operation and of actions tak'en to control those effects.

Environmental concerns identified in the FES which relate to water quality matters are regulated by way of the licensee's NPDES permit.

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I 2.0 Environmental Protection Issues l

In the FES-OL dated October, 1975, the staff considered the environmental impacts associated with the operation of the one-unit Davis-Besse Nuclear Power Station. Certain environmental issues were identified which required study or license conditions to resolve environmental concerns and to assure adequate protection of the environment. The Appendix B Environmental Techni-cal Specifications issued with the license included monitoring programs and other requirements to permit resolution of the issues.

Aquatic issues are now addressed by the effluent limitations, monitoring requirements and the Section 316(b) demonstration requirement contained in the effective NPDES Permit issued by the State of Ohio Environmental Protection Agency. The NRC will therefore rely on this agency for regulation of matters involving water quality and aquatic biota.

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p 3.0 Consistency Requirements -l 3.1 Plant Design and Operation The licensee may make changes in station design or operation or perform tests or experiments affecting the environment provided such changes, tests or experiments do not involve an unreviewed environmental question, and do not involve a change in the Environmental Protection Plan.* Changes in plant design or operation or performance of tests or experiments which do not affect the environment are not subject to the requirements of this EPP.

Activities governed by Section 3.3 are not subject to the requirements of this section.

Before engaging in additional construction or operational activities which may affect the environment, the licensee shall prepare and record an environ-mental evaluation of such activity.** When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide a written evaluation of such activities and obtain prior approval from the Director, Office of Nuclear Reactor Regulation.

A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question if it concerns (1) a matter which may result in a significant increase in any adverse environmental impact previously evaluated <

in the final environmental statement (FES) as modified by staff's testimony'to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or power level [in acccordance

This provision does not relieve the licensee of the requirements of .10 CFR 50.59.

- Activities are excluded from this requirement if all measurable nonradiological effects are confined to the on-site areas previously disturbed during site preparation and plant construction.

3-1

with 10 CFR Part 51.5(b)(2)) or (3) a matter not previously reviewed and evaluated in the documents specified in (1) of this Subsection, which may have a significant adverse environmental impact.

The licensee shall maintain records of changes in facility design or operation and of tests and experiments carried out pursuant to this Subsection. These records shall include a written evaluation which provide bases for the deter-mination that the change, test or experiment does not involve an unreviewed environmental question. The licensee shall include as part of his Annual Environmental Operating Report (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.

3.2 Reports Related to the NPDES Permits Violations of the NPDES Permit (pursuant to Section 401 of the Clean Water Act) shall be reported to the NRC by submittal of undocketed copies of the reports required by the NPDES Permit.

The NRC will receive undocketed copies of changes and additions to the NPDES Permit within 30 days following the date that the change is receivcd by the licensee. If the permit, in part or in its entirety, is appealed and stayed, the NRC will receive an undocketed copy of the correspondence within 30 days following the date the stay is granted and received by the licensee.

The NRC shall be notified of changes to the effective NPDES Permit proposed by the licensee by providing NRC with an undocketed copy of the proposed change at the same time it is submitted to the permitting agency. The notifi-caIion of a licensee-initiated change shall include an undocketed copy of the requested revision submitted to the permitting agency. The licensee shall 3-2

b provide the NRC an undocketed copy of the application for renewal of the NPDES permit at the same time the application is submitted to the permitting agency.

3.3 Changes Reouired for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal, State, or local environmental regulations are not subject to the requirements of Section 3.1.

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j 4.0 Environmental Conditions 4.1 Unusual or important Environmental Events Any occurrence of an unusual or important event that indicates or could result in significant environmental impact causally related to plant operation shall be. recorded and promptly reported to the NRC within 5 days by tele-phone, telegraph, or facsimile transmissions followed by a written report.

i The following are examples: excessive bird impaction events, onsite plant

) or animal disease outbreaks, mortality or unusual occurrence of any species 1

j protected by the Endangered Species Act of 1973, fish kills, increase in ,

nuisance organisms or conditions and unanticipated or emergency discharge of I waste water or chemical substances.

l No routine monitoring programs are required to implement this condition.

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1 l-5.0 Administrative Procedures f This Section applies to Appendix B, Part 2, non-radiological, only 5.1 Review and Audit The licensee shall provide for review and audit of compliance with the Environmental Protection Plan. The audits shall be conducted independently of the individual or groups responsible for performing the specific activity. A description of the organization structure utilized to achieve the independent review and audit function and results of the audit activities shall be maintained and made available for inspection.

5.2 Records Retention Records and logs relative to the environmental aspects of plant operation shall be made and retained in a manner convenient for review and inspection.

These records and logs shall be made available to NRC on request.

Records of modifications to plant structures, systems and components determined to potentially affect the continued protection of the environment shall be retained for the life of the plant. All other records, data and logs relating to this EPP shall be retained for five years or, where applicable, in accordance with the requirements of other agencies.

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5.3 Changes in Environmental Protection Plan Request for change in the Environmental Protection Plan shall include an

-assessment of the environmental impact of the proposed change and a supporting justification. Implementation of such changes to the Environmental Protection Plan shall not commence prior to NRC approval of the proposed changes in the form of a license amendment incorporating the appropriate revision to the Environmental Protection Plan.

5.4 Plant Reporting Requirements 5.4.1 Routine Reports An Annual Environmental Operating Report describing implementation of this EPP for the previous year shall be submitted to the NRC prior to May 1 of each year. Tt.e initial report shall be submitted prior to May 1 of the year following issuance of the operating license. The period of the first report 1

shall begin with the date of issuance of the operating license.

The report shall include summaries and analyses of the results of the environmental protection activities required by Section 4.0 of this Environ-mental Protection Plan for the report period, including a comparison with I preoperational studies, operational controls (as appropriate), and previous non-radiological environmental monitoring reports, and an assessment of the observed impacts of the plant operation on the environment. If harmful effects or evidence of trends towards irreversible damage to the environment are observed, the licensee shall provide a detailed analysis of the data and a proposed course of action to alleviate the problem.

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Dockst No. 50-346 License No. NPF-3.

Serial No. 979 August 18, 1983 Attachment IV I. Changes to Davis-Besse Nuclear Power Station Unit 1, Appendix A ""

Technical Specifications A. Time required to Implement. 1This change is to be effective upon NRC approval.

B. Reason for Change (Facility Change Request 83-070).

Corrects a typographical error for the containment isolation valves in penetration #74B.

C. Safety Evaluation (See attached)

D. Significant Hazards Considerations (See attached) ,

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l SAFETY EVALUATION This amendment request is to correct a typographical error in the Technical Specification Section 3.6.3.1, Table 3.6-2 for the containment isolation valves in penetration #7411. There are two valves labeled CV5011D where one of which should be CV5010D. Valve CV5011D is located inside contain-ment and CV5010D is located outside of the containment.

The safety function of valves CV5010D and CV5011D is for containment isolation following a LOCA. They are part of the containment gas analyzer system.

Since the proposed change is due to a typographical error, there is no change in system hardware and function, or the system operating procedure.

Based on the above, it is concluded that this change in the Technical Specification does not present any unreviewed safety questions.

[r SIGNIFICANT HAZARD CONSIDERATION The attached amendment request to correct a typographical error in the Davis-Besse Technical Specification Table'3.6-2 does not contain a Significant Hazard. The revision only changes a Containment Air Sample Valve Number which is incorrectly labeled. This change is purely an administrative change to the technical specifications which is in accordance with examples of amendments that are considered not likely to involve Signficiant Hazards Considerations published in the Federal Register.

The granting of the request would not:

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

This request does not contain increase in the probability or conse-quences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident pre-viously evaluated 10CFR50.92(C)(2).

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

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

This request will maintain the margins assumed in the accident analysis.

Therefore, based on the attached safety evaluation and the above, the requested amendment does not contain a Significant Hazard.

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TABLE 3.6-2 l

CONTAINMENT ISOLATION VALVES (Continued) .

PENETRATION VALVE ISOLATION NUMBER NUMBER -FUNCTION TIME (seconcs) 67 CV5090 Hydrogen Oilution System Supply 60 68A SS235A Pressurizer Quench Tank Sample 30 68A S52358 Pressurizer Quench Tank Sample 30 68B CV50108 Containment Air Sample 15 68B CV5011B Containment Air Sample ,15 69 CV5065 Hydrogen Dilution System Supply 60 71 S CV5010A Containment Air Sampie 15

. 713 CV5011A Containment Air Sample 15 71C CV1544 Core Flood Tank N2 Fill 10 735 CV5010C Containment Air Sample 15 733 CV50 llc Containment Air Sample 15 743 GT9HD C'!w. c Containment Air Sample

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743 CV50110 Containment Air Sample 15 B. CONTAINMENT PURGE AND EXHAUST ISOLATION l 33 ## CV5005 Containment Vessel Purge Inlet Line 10 ,

) 33 !?. CV5006 Containment Vessel Purge Inlet Line 10 l 34 if CV5007 Containment Vessel Purge Outlet Line 10 l 34 !! CV5008 Containment Vessel Purge Outlet Line 10

! C. OTHER

! 5 i SW1366 Containment Air Cooling. Units SW j Inlet Line N/A 6 i SW1368 Containment Air Cooling Units SW Inlet Line -

N/A 7 i SW1367 Containment Air Cooling Units SW Inlet Line N/A 9 i SW1356 Containment Air Cooling Units SW

, Outlet Line N/A l .

I DAVIS-BESSE, UNIT 1 3/4 6-19 Amendment No. 31

Dockst No. 50-346 License No. NPF-3 Serial No. 979 August 18, 1983 Attachment V I. Changes to Davis-Besse Nuclear Power Station Unit 1, Appendix A Technical Specifications A. Time required to Implement. This change is to be effective upon NRC approval.

B. Reason for Change (Facility Change Request 82-158).

To provide for a shutdown of the unit, if required, due to equipment inoperability that places the plant both outside the Limiting Condition for Operation and the applicable Action Statement.

C. Safety Evaluation (See attached)

D. Significant Hazards Considerations (See attached) l L

SAFETY EVALUATION This amendment request changes two Sections, 3.0.3 and 4.0.3, and adds Section 3.0.5, of the Davis-Besse (DB) Technical Specifications. The safety function of Section 3.0.3 and 3.0.5 is to provide for a shutdown of the unit, if required, due to equipment inoperability that places the plant both outside the Limiting Condition for Operation and the applicable Action Statement.

The DB Technical Specifications currently require the unit to be placed in Hot Standby (Mode 3) within one hour of the time the plant goes outside the bounds of the Action Statement. If the plant is operating st high power levels, it cannot be shutdown in a controlled manner within one hour. Compliance with the one hour requirement, therefore, places a potential challenge to safety that the Technical Specification Limiting Conditions for Operation and the Action Statement are designed to prevent.

The B&W STS (Rev. 4), however, allows six hours to reach Mode 3 with the provision that actions be initiated to place the unit in Mode 3 within one hour. Since the six hour time period allows a more orderly shutdown, the potential for challenge to Davis-Besse's safety systems, based on engineering judgement, is lowered, thereby increasing the margin of safety.

The safety function of Section 4.0.3 is to provide guidance in the deter-mination of equipment / system operability in the event of missed surveillance tests. This amendment adds up to a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period to allow the missed test to be performed before entry into the shutdown statement is required.

This period will help avoid an unnecessary transient on the plant, and therefore, a potential challenge to safety systems. This provision is allowed for surveillance tests of a performance interval of one month or longer. Those tests performed more frequently will be required to be performed within the time interval allotted as discussed in the associated ACTION requirements. Engineering judgement dictates that the relative risk due to potential inoperability of a missed surveillance test is lower than the risk due to a plant shutdown created transient before a surveil-lance can be performed to confirm the actual condition of the equipment.

The twelve (12) hour time period has been arrived at following a review of various surveillance test procedures along with the normal completion times to perform each of the tests. Examples of surveillance tests are included with completion times:

ST 5031.14 SFRCS Monthly Test 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ST 5031.19 ARTS Monthly Functional Test 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ST 5031.03 Containment Pressure to SFAS Calibration 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months In addition to these completion times, a four hour time period was deemed necessary in order to allow for the appropriate off site personnel to be eclled and arrive on site, calibrate test equipment, prepare test paperwork, set up test prerequisites and plant lineups, and obtain applicable approvals permitting test performance.

1 Section 3.0.5. to be added to the Davis-Besse (DB) Technical Specifications details the operability and action requirements for systems and equipment

- =_ -- - =. . ._ .__ . . -

when either its normal or emergency power supply is inoperable. It allows operation to be governed by the time limits of the ACTION statement associated with the Limiting Condition for Operation for the normal or emergency power source, not the individual ACTION statements for each system, subsystem, train, component or device that is determined to be inoperable solely because of the inoperability of its normal or emergency power source. The safety function for this Section 3.0.5 will provide consistent operation and interpretation of the Limiting Condition for Operation for the system affected by a loss of normal or emergency power supply. No new requirements are added, only clarified and simplified.

Therefore, based on engineering judgement, the margin of safety of Davis-Besse will not be decreased by this amendment.

Based on the above, it is concluded that this change in the Technical Specification does not present any unreviewed safety questions.

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SIGNIFICANT HAZARD CONSIDERATION f

The attached request is a revision to a previous submittal dated July 1,

+

1983 (Serial No. 961) and does not contain a significant hazard. Technical-

!- Specification Section 3.0.5 is being added to Appendix A. Toledo Edison is 4

adding this section which is part of the Standard Technical Specification. ,

j The Limiting Condition for Operation was not part of our original specifi-j cations but the intent was part of our operating policy. This part of the request formalizes this action.

l Contained within the application is a revision to Section 4.0.3.1 which

] adds "This applies only to those Surveillance Requirements performed on a

, _ monthly or longer periodic interval". The additional time (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) to perform administratively missed surveillances will help avoid an unnecessary transient on the plant and therefore, a potential challenge to j the safety system. This provision is allowed for surveillance tests of a j performance interval of one month or longer. Those tests performed more

frequently will be required to be performed within the time interval allotted as discussed in the associated ACTION requirements.

The granting of the request would not:

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

4 j No accident or accident analysis is affected by this change. Only I the time requirements to enter into a specific mode changing action f statement are altered to permit a more orderly shutdown and to

] eliminate unnecessary transients. The additional time allowed to j perform monthly or longer surveillance internal tests does not j represent a significant time change.

i

{ 2) Create the possibility of a new or different kind of accident pre-

! viously evaluated.10CFR50.92(C)(2) .

1 l All accidents are still bounded by previous and no new accidents are involved.

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

1 I

This request will maintain the margins assumed in the accident analysis.

4 Therefore, based on the attached safety evaluation and the above, the i requested amendment does not contain a Significant Hazard.

4 I

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3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE i I

3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.1 Limiting Conditions for Operation and ACTION requirements shall be applicable during the OPERATIONAL MODES or other conditions speci each specification.

Adherence to the requirements of the Limiting Condition for Opera-3.0.2 tion and/or associated ACTION within the specified time interval shallIn constitute ccmpliance with the specification. Condition for Oper

time interval, completion of the ACTION statement is C'not required. n 3.0.3 In the event a Limiting Condition for Operation and/or associated

/ ACTION requirements cannot be satisfied because of circumstances in

/

excess of those addressed in the specification, the facility shall be placed in at least HOT STANDBY within i hour and in COLD SHUTDOWN the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months unless corrective measures are ccepleted that <

j permit operation under the permissible ACTION statements Exceptions tofor the I speci-fied time interval as measured from initial discovery.

these requirements shall be stated in the individual V specificaticns. U2.

i'

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3.0.4 Entry into an OPERATIONAL MODE or other specified applicabilityC 7

condition shall not be made unless the conditions3,ofo,1the the ACTION statements unless otherwise excepted. This provision shall not prevent passage through OPERATIONAL MODES as required to comply w ACTION statements. 1,O.b' j hI4 #N1S f._ d A 0_

SURVEILLANCE RE0VIREMENTS 4.0.1 Surveillance Requirements shall be applicable during the OPERA-TIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Sur-veillance Requirement.

4.0.2 Each Surveillance Requirement shall be performed within the specified time interval with:

a. A maximum allowable extension not to exceed 25% of the s lance ir.terval, and i /

b. A total maximum combined interval time for any 3 consecutive l >

tests not to exceed 3.25 times the specified surveillance interval .

DAVIS-BESSE, UNIT 1 ,

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3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit in a MODE in which the Specification does not apply to placing it, as applicaole, in:

1. At least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2. At least EDT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Specifications.

1

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION 3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considerea OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system (s), subsystem (s), train (s), component (s) and devica(s) are OPERABLE, or likewise satisfy the requirements of this specification. Unless both conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it as applicable in:

1. At least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This Specification is not applicable in MODES 5 or 6.

o - .

3/~.0 AF?LICA5ILITY BASES The specifications of this section provide the general recuirements applicable to eacn of the Limiting Conditions for Operation and Surveil-lance P.equirements within Section' 3/4.

3.0.1 This specification defines the applicability of each specifi:a-tion in terms of defined OPE?ATIO AL I40 DES or etner specified conditions and is provided to delineate specifically wnen each specification is applicable.

3.0.E This specification defines tnese condi:icr.s ne:essery o constitute : mpliance ni:n the terms cf an individuc1 Limi:ing Con:ition for Operatica. and associated ACTICN requirement.

f -

- 3.0.3 This specification delineates the ACTICri to be taken for circumstances not dire::ly previded for in the ACTIOf; s:atsmer.:s anc j whese ec:urrence would viola:s the inten of the cpecifica:icn. For example, Saecifica:icn 3.5.1 calls for each Reac: r C:oian: System core fleeding tank to be OPE?ABLE and provides explici: ACTIO:? recaire-ments wnen one tank is inoceracie. Under the terms of Specificati n 3.0.3, if more than one tank is inoceracle, the facility is re:vired ,

to be in a: least HOT STAT DBY within 1 nour and in COLD SHUT 00W D the followinc 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

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donb*1 3.0.a This see:ification provides that entry into an GPE?ATIOi!AL MODE cr otner specified applicacility condition must be made witn (a) the

$cM full complement of re:uired systems, ecui: men: cr ccmcor.ents C?EF.AELE and (b) all otner parameters as specified in the Limiting Conditions for

% )j Operation being met witncut regard fer alic. table deviations and out of service provisions contained in tne ACTIO*i statemen;s.

The intent of this provision is to insure that facility operation is not initiated with either required equipment or systems inoperable or other specified limits being exceeded.

Exceptions to this provision have been provided for a limited number of specifications when startup with inoperable equipment would not affect plant safety. These exceptions are stated in the ACTI0tt statements of the appropriate specifica-icns.

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l DAVIS-BESSE, U:4IT 1 -

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3.0.3 This specification delineates the ACTION to be taken for circum-stances not directly provided for in the ACTION stacaments and whose occurrence would violate the intent of the specification. For example, Specification 3.5.1 requires each Reactor Coolant System core flooding j tank to be OPERABLE and provides explicit ACTION requirements if one tank is inoperable. Under the terms of the Specification 3.0.3, if more than one tank is inoperable, the unit is required to be in at least HOT STANDBY ,

within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . l As a further example, Specification 3.6.2.1 requires two Containment Spray I Systems to be OPERABLE and provides explicit ACTION requirements if one l spray system is inoperable: Under the terms of Specification 3.0.3, if both of the required Containment Spray Systems are inoperable, the unit is ,

required to be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in at least COLD SHUTDOWN in the following'24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . It is assumed that the unit is brought to the required MODE within the required times by promptly initiating and carrying out the appropriate ACTION statement.

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APPLICABILITY BASES 3.0.5 This specification delineates what additional conditions must be satisfied to permit operation to continue, consistent with' the- ACTION' statements for power sources, when.a normal or emergency power source'is, nct OPERABLE.

It specifically prohibits operation when one division'is inoperabli because its normal or emergency power source is iroperable and a syst'em, subsystem, ,

train, component or device in another division is inoper'able for another !

reason.

The provisions of this specification permit the ACTION statements associated with individual systems, subsystems, trains, components, or cevices to be consistent with the'ACTICN" statements of the associated electrical power source. It allows operation to be governed by the time limits of the ACTION statement associated with the Limiting Condition for Operation for the normal -

or emergency power source, not the, individual ACTION statements for each system, subsystem, train, enmponent or device that is determined to be inoper-able solely because of the inoperability of its normal or emergency power source.

For example, Specification 3.8.1.1 requires in part that two emergency diesel generators be OPERABLE. The' ACTION statement provides for a 72-hour out-of-service time when one emergency diesel generator is not OPERABLE. If the definition of C,PERA8LE were applied without consideration of Specification 3.0.5, all systems, subsystems, trains, cocoonents and devices supplied by the

}

inoperable emergency power source would als'c be inoperable. This would dictate invoking the applicable ACTION statements for each of the applicable Limiting Conditions for Operation. However, the provisions of Specification 3.0.5 ~

permit the time' limits for continued operation to be ccasistent with the ACTION statement'fo,r the inoperable emergency diesel generator instead, provice_d the other specified conditions are satis' fied. .In this case, this would mean that the corresponding normal power source,must be OPERABLE, and all redundant systems, subsystems, trains, components, and devices must be OPERABLE, org otherwise satisfy Specification 3.0.5 (i.e., be capqble of performing their '

cesign furction and 'have at least one normal or one/ emergency power source OPERABLE). If they are not satisfied, action is required in accordance with

[ this specification. '

As a 'further example, Specification '3'.8.1.1 requires inL oart. that two physically independent circuits between the of fsite transmission network and ^the onsite Class IE distrioutioi system be OPERASLE. The ACTICN statement provides a 24-nour out-of-service time when both required offsite? circuits are not OPERABLE.

If the oefinition of OPERABLE were applied without co'nsideration of. Specif,1 cation 3.0.5. all systems, suosystems, trains, componentssand' devices supp, lied by the 1 inocerable normal power sources, both of the offsite circuits, would also be 1 inoperacle. This would dictate invoking the applicable ACTION statements for '

eacn of the applicable LCOs. However, the provisions of Specification 3.0.5 l permit the time limits for continued operation to be, consistent with the '

ACTION statement for the inoperable norm'al power Sources insteao, provided the B 3/4 0-2

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8 BASES '

4 other specified conditions are satisfied. In this case, this would mean that

, for one division the emergency power source must be OPERABLE (as must be the

~

components supplied by the? emergency power source) and all redundant systems, subsystems, trains, components and devices in the other division must be OPERABLE, or likawise satisfy Specification 3.0.5 (i.e. , be capable of per-forming their design functions and have an emergency power source OPERABLE).

In other words, both emergency power sources must be OPERABLE. In other words,

- both emergency power sources must be OPERABLE and all redundant systems, sub-systems, trains, components and devices in both divisions must also be OPERABLE.

If these , conditions are not satisfied, action is recuired in accordance with this specification.

In MODES 5 or.6, Specification 3.0.5 is not applicable, and thus the individual

~

ACTION statements for each aoplicable Limiting Condition for Operation in w these MODES must be adhered to.

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' APPLICABILITY SURVEILLA'1CE REOUIREMENTS (Continued)

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A r[, 4.0.3 Performance of a Surveillance Requirement within the specified time interval shall constitute ccmpliance with OPERABILITY requirements ,

for a Limiting Condition for Operation and associated ACTION statements > I unless otherwise required by the specification.

.m+ r = w 4.0.4 Entry into an OPERATIONAL MODE or other specified applicability D condition shall not be made unless the Surveillance Requirement (s) asscciated with the Limiting Condition for Operation have been perfomed

! 4h AuC {j><ithin the stated surveillance interval or as otherwise specified.

4,0, p 4.0.5 Surveillance Requirements for inservice, inspection and testing of ASME Code Class 1, 2 and 3 ccmpenents shall be applicable as follows:

h8, a. During the time period:

~

1. Frem issuance cf the Facility Ocerating License to the start of facility ccamercial operation, inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be perfor=ed in accordance witn Section XI of the ASME Boiler and Pressure Vesel Code 1974 Edition, and Addenda through Summer 1975, exccot wnere specific written relief has been granted by the Ccmmiss' ion.

2. Following start of facility ccamercial; operation, inservice inspection of ASME Code Class 1, 2 and 3 ccmoonents and inservice testing of ASME Code Class 1, 2 and 3 pumas and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and acclicable Addenda as required by 10 CFR 50, Section 50.55a(g),

except where specific written relief has been granted by the Commission pursuant to 10 CFR S0, Section 50.55a(g)(6)(i).

~

b. Surveillance intervals specified in Section XI of the ASME

' Boiler and Pressure Vessel Code and applicable Addenda for the inservice inspection and testing activities required by the

' ASME Boiler and Pressure Vessel Code and applicable Addenda shall be applicable as foilcws in these Technical Specifications:

4

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DAVIS-BESSE? UNIT 1 3/4 0-2 1

i

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4.0.3 Failure to perform a Surveillance Requirement within the specified time interval shall constitute a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation.

Exception to these requirements are stated in the individual Specifications. Surveillance Requirements do not have to be 4

performed on inoperable equipment.

4.0.3.1 If the failure to perform the Surveillance Requirement within i the specified time limit is due to an administrative error, the j applicable action shall be as follows:

l With a piece of equipment or a system inoperable due to a

'I missed Surveillance Requirement, perform the re-

] quired surveillance within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from the time of discovery.

This applies only to those Surveillance Requirements performed on a monthly or longer periodic interval.

NOTE: If a Surveillance Requirement is missed due to

. an administrative error, appropriate reports must be filed

! even if the surveillance is performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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D:ckst No. 50-346 License No. NPF-3 Serial No. 979 i

August 18, 1983

. Attachment VI I. Changes to Davis-Besse Nuclear Power Station Unit 1, Appendix A Technical Specifications incorporation of Radiological Effluent Techynical Specifications (RETS).

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

B. Reason for Change (Facility Change Request 79-114).

Amend the proposed RETS concerning the source check requirement prior to using the containment purge vent system.

C. Safety Evaluation (See attached)

D. Significant Hazards Considerations

. (See atta:hed) i i

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l SAFETY EVALUATION This amendment request revises the proposed Radiological Effluent Technical Specification (RETS) 4.3.3.10, Table 4.3-16, Item 3, concerning the source check requirement prior to using the containment purge vent system.

The safety function of the purge exhaust radiation monitor is to accurately determine the actual amount of radioactive effluents prior to entering the containment purge exhaust filters. The safety function associated with the source check is to perform a functional check of the radiation monitor by exposing it to a radiation source to determine if the monitor is functioning.

The containment purge exhaust system was originally io? ended to be used periodically during power operation to purge the cor' .1. ment, and the present Technical Specification requires that a sea, <

. .ack be performed prior to using the system for this function. Sine containment purging was originally limited to less than 90 hours0.00104 days 0.025 hours 1.488095e-4 weeks 3.4245e-5 months / year while at power and is now prohibited, this frequency for source check'.ng was adequate. However, the containment purge exhaust system is now continuously used to purge the negative pressure boundary area and the functional check of the radiation monitor prior to using the purge exhaust system is not adequate to determine if the monitor is functioning properly.

The Radiological Technical Specification should be changed to require the source check to be performed as follows:

1. Prior to using the purge exhaust system for containment or negative pressure boundary areas, if it was not performed within the last 30 days.

2. Monthly during the use of the purge exhaust system for contain-ment or negative pressure boundary areas.

The increased frequency in performing the source check of the radiation moaitor will increase the probability that the monitor is functioning properly.

This change does not affect the setpoints established for this radiation monitor and it does not adversely affect its safety functions.

Based on the above, it is concluded that this change in the Radiological Technical Specification does not present an unreviewed safety question.

l

l l

SIGNIFICANT HAZARD CONSIDERATION

, The attached amendment request for a change to the Radiological Effluent Technical Specification (RETS) does not contain a Significant Hazard. The requested changes are to the RETS (which is under review by the NRC) to i revise Table 4.3-16, Item 3 name change and the period for source check to reflect the present operating conditions.

The containment purge exhaust system was originally intended to be used periodically during power operation to purge the containment, and the 4

present Technical Specification requires that a source check be performed prior to using the system for this function. However, the containment l purge exhaust system is now continuously used to purge the negative j pressure boundary area and the functional check of the radiation monitor ,

prior to using the purge exhaust system is not adequate to determine if the monitor is functioning properly. The increase frequency in performing the source check of the radiation monitor is an increase in the surveillance j requirements.

The granting of the request would not:

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

No accident or accident analysis is adversely affected by this request.

l The increased surveillance will have a positive impact on equipment operability.

2) Create the possibility of a new or different kind of accident pre-viously evaluated 10CFR50.92(C)(2).

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

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

This request will maintain the margins assumed in the accident analysis.

Therefore, based on the attached safety evaluation and the above, the i requested amendment does not contain a Significant Hazard.

i 1

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TABLE 4.3-16 -

g RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREE NTS -

C; k CHANNEL M CHANNEL SOURCE CHANNEL FUNCTIONAL

.m INSTRUENT CHECK CHECK CALIBRATION TEST

1. Waste Gas Decay' System

~

a. Noble Gas Activity Monitor P III P R(5) g(3)

! b. Effluent System Flow Rate P II} N/A R Q

2. Waste Gas System

a. O gen Monitor D(2) N/A Q(6) N/A en Ale,e Ge- Pre s s vre. Bu,aL., g ,

3. ContainmentTPurge Vent System #

a. Noble Gas Activity Monitor D II) + R(5) g(3)

4. Station Vent Stack

a. Noble Gas Activity Monitor D II) M R(b) 0

b. Iodine Sampler W(1) /A /A N/A

c. Particulate Sampler W II) N/A N/A N/A

d. System Effluent Flow kate Measurement Device D(j) N/A R N/A

e. Sampler Flow Rate Measurement Device W(j) N/A R N/A W gu

I 1

TABLE 4.3-16 (Continued) l TABLE NOTATION (1) During radioactive waste gas releases via this pathway.

(2) During additions to the waste gas surge tank.

(3) The CHANNEL FUNCTIONAL. TEST shall also demonstrate that automatic isolation of this pathway and control room alann annunciation occurs if the instrument indicates measured levels above the alam/ trip setpoint.

(4) The CHANNEL FUNCTIONAL TEST shall also demonstrate that control room alam annunciation occurs if the instrument indicates measured levels above the alam/ trip setpoint.

(5) The initial CHANNEL CALIBRATION for radioactivity measurement instrumentation shall be performed using one or more of the reference standards certified by the National Bureau of Standards or using standards that have been obtained from suppliers that participate in measurement assurance activities with NBS. These standards should pennit calibrating the system over its intended range of energy and rate capabilities. For subsequent CHANNEL CALIBRATION, sources that have been related to the initial calibration should be used, at intervals of at least gnce per eighteen months. This can normally be accomplished during refueling outages. For high range monitoring instrumen-tation, where calibration with a radioactive source is imprac-tical, an electronic calibration may be substituted for the radiation source calibration.

(6) The CHANNEL CALIBRATION shall include the use of standard gas samples containing a nominal:

1. One volume percent oxygen, balance nitrogen; and

2. Four volume percent oxygen, balance nitrogen.

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DAVIS-BESSE, UNIT 1 l

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v t e Letter Sequence Other
TAC:52417, (Open) TAC:53296, (Open) TAC:56794, (Open)
Initiation Request, Request, Request, Request Acceptance... Administration Questions Answers Results Approval... Other: ML20076F393, ML20099L151
MONTHYEAR1983-08-18 [Table View]

ML20076F393

Text

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