ML20217A552

Forwards Revised TS Page B 3/4 9-1

ML20217A552
Person / Time
Site:	Davis Besse
Issue date:	03/19/1998
From:	Hansen A NRC (Affiliation Not Assigned)
To:	Jeffery Wood CENTERIOR ENERGY, TOLEDO EDISON CO.
References
TAC-M99556, NUDOCS 9803250107
Download: ML20217A552 (8)

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UNITED STATES

,j NUCLEAR REGULATORY COMMISSION 2

WASHINGTON, D.C,30eedHlo01 March 19, 1998 Mr. John K. Wood Vice President - Nuclear, Davis-Besse Centerior Service Company c/o Toledo Edison Company Davis-Besse Nuclear Power Station 5501 North State Route 2 Oak Harbor OH 43449-9760

SUBJECT:

BASES CHANGE TO TECHNICAL SPECIFICATIONS FOR FACILITY OPERATING LICENSE NO. NPF DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 (TAC NO. M99556)

Dear Mr. Wood:

i By letter dated August 26, 1997, you submitted License Amendment Request 97-14 to change Technical Specification (TS) 3/4.6.1.3, " Containment Systems -

Containment Air Locks," TS Bases 3/4.6.1.3, " Containment Systems - Containment Air Locks," and TS Bases 3/4.9.4, " Refueling Operations - Containment Penetrations." The containment air lock Limiting Condition for Operation and Surveillance Requirements would be modified, and the associated bases would be changed.

The review of the proposed changes to TS 3/4.6.1.3 and TS Bases 3/4.6.1.3 is ongoing, and will be the subject of future correspondence.

The review of TS Bases 3/4.9.4 is complete, as discussed below.

This change may be made separately from the TS changes because, as stated in 10 CFR 50.36 bases for the TSs shall be included with, but shall not become par (a), the t of the TSs.

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TS Bases 3/4.9.4 currently reads, in part:

A A containment personnel air lock door is considered capable of being closed if the door is unblocked and there are no cables or hoses being run through the air lock.

You have proposed to change this sentence to read:

A containment personnel air lock door is considered capable of being closed if the door is not blocked in such a way that it cannot be expeditiously closed, and any hoses and cables running through the air lock employ a means to allow safe, quick disconnect or severance, and are tagged at the air lock with specific instructions to expedite removal.

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7 J. Wood This change will allow hoses and cables to be run through the air lock, subject to the restrictions stated.

If accepted, this change will increase operational flexibility during plant outages.

The staff has previously determined that cable and hose routing through the personnel air lock door,.as you propose, is acceptable during core alterations or movement of irradiated fuel within containment, provided the TSs allow both doors to be open, specify that a designated individual will be stationed outside the air lock, and that at least one door is capable of being closed.

See, for example, the Safety Evaluation for amendments to the facility.

operating licenses of Turkey Pois.t, Units 3 and 4 (Docket Nos. 50-250 and 50-251), dated May 11, 1995.

Davis-Besse TS 3.9.4 states that, during core alterations or movement of irradiated fuel within the containment:

The containment penetrations shall be in the following status:

a.

b.

A minimum of one door in each air lock closed, but both doors of the containment personnel air lock may be open provided that at least one personnel air lock door is capable of being closed and a designated individual is available immediately outside the personnel air lock to close the door, and....

Since the Davis-Besse TSs allow both air lock doors to be opened with the j

restrictions discussed above, the proposed bases change is consistent with the j

current staff position for hose and cable routing through air locks during core alterations or movement of irradiated fuel in containment. Therefore, it is acceptable.

The lines and hoses run through the air lock should be minimized, and the quick disconnects should be located near the air lock to ensure timely closing of an air lock door.

You should also ensure that these lines and hoses do not serve any personnel or equipment safety function which could be interrupted by disconnection.

In addition, your administrative guidelines should clearly identify responsibility for disconnecting these lines.

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3 J. Wood March 19, 1998 Please contact me if you hatte any questions regarding this issue.

Sincerely, Original Signed by Allen G. Hansen, Project Manager Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

Revised TS Page B 3/4 9-1 cc w/ encl:

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Please contact me if you have any questions regarding this issue.

Sincerely, Original Signed by Allen G. Hansen, Project Manager Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor f.egulation Docket No. 50-346

Enclosure:

Revised TS Page B 3/4 9-I cc w/ encl: See next page Distribution w/encls:

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J. Wood

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Please contact me if you have any questions regarding this issue.

Sincerely,

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Allen G. Hansen, Project Manager Project Directorate III-3 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

Revised TS Page B 3/4 9-I cc w/ encl: See next page e

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John K. Wood Davis-Besse Nuclear Power Station, Unit 1 Toledo Edison Company cc:

Mary E. O'Reilly Robert E. Owen, Chief FirstEnergy Bureau of Radiological Health Davis-Besse Nuclear Power Station Service 5501 North State - Route 2 Ohio Department of Health Oak Harbor, OH 43449-9760 P.O. Box 118 Columbus, OH 43266-0118 James L. Freels Manager-Regulatory Affairs Toledo Edison Company James R. Williams, Chief of Staff Davis Besse Nuclear Power Station Ohio Emergency Management Agency 5501 North State - Route 2 2855 West Dublin Granville Road Oak Harbor, OH 43449-9760 Columbus, OH 43235-2206 Gerald Chamoff, Esq.

Donna Owens, Director Shaw, Pittman, Potts Ohio Department of Commerce and Trowbridge Division of Indusirial Compliance

- 2300 N Street, NW.

Bureau of Operations & Maintenance Washington, DC 20037 6606 Tussing Road P.O. Box 4009 Regional Administrator Reynoldsburg, OH 43068-9009 U.S. Nuclear Regulatory Commission 801 Warrenville Road Ohio Environmental Protection Agency Lisle, IL 60523-4351 DERR-Compliance Unit ATTN: Zack A. Clayton Robert B. Borsum P.O. Box 1049 Babcock & Wilcox Columbus, OH 43266-0149 Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 State of Ohio Rockville, MD 20852 Public Utilities Commission 180 East Broad Street Resident inspector Columbus, OH 43266-0573 U.S. Nuclear Regulatory Commission 5503 North State Route 2 Attomey General Oak Harbor, OH 43449 Department of Attomey 30 East Broad Street James H. Lash, Plant Manager Columbus, OH 43216 Toledo Edison Company Davis-Besse Nuclear Power Station President, Board of County 5501 North State Route 2 Commissioner of Ottawa County Oak Hart >or, OH 43449-9760 Port Clinton, OH 43252

I FACILITY OPERATING LICENSE NO. NPF-3 DOCKET NO. 50-346 Replace the following page of the Technical Specifications Bases with the attached page. The revised page contains a vertical line indicating the area of change.

Remove Insert TS B 3/4 9-1 TS B 3/4 9-1 s

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i 1

ENCLOSURE

3/4.9 REFUELING OPERATIONS BASES a

3/4.9.1 BORON CONCENTRATION The limitation on reactivity during REFUELING ensures that: 1) the reactor will remain suberitical during CORE ALTERATIONS, and 2) a uniform boron concentration is maintained for reactivity control in the water volumes having direct access to the reactor vessel. This limitation is consistent with the initial conditions assumed for the boron dilution incident in the accident analysis.

The ACTION statement's minimum boration flow rate of 12 gpm is less than the minimum boration flow rate of 25 gpm specified in TS 3/4.1.1.1, Reactivity Control -

Shutdown Margin because the lower flow rate is based on only borating the reactor vessel.

3/4.9.2 INSTRUMENTATION The OPERABILITY of source range neutron flux monitors ensures that redundant monitoring capability is available to detect changes in the reactivity condition of the core.

3/4.9.3 DECAY TIME The minimum requirement for reactor subcriticality prior to movement of irradiated fuel assemblies in the reactor pressure vessel ensures that sufficient '

time has elapsed to allow the radioactive decay of the short lived fission products.

This decay time is consistent with the assumptions used in the safety analyses.

3/4.9.4 CONTAINMENT PENETRATIONS During CORE ALTERATIONS or movement of irradiated fuel within the containment, release of fission product radioactivity to the environment as a result of a fuel element rupture must be minimized. During MODES 1, 2, 3, and 4, this is accomplished by maintaining CONTAINMENT INTEGRITY as described in LCO 3.6.1.1.

In other situations, the potential for containment pressurization as a result of an accident is not present, and therefore less stringent requirements are needed to isolate the containment from the atmosphere outside containment.

Both containment personnel air lock doors may be open during CORE ALTERATIONS or during movement of irradiated fuel within the containment provided the conditions-specified in LCO 3.9.4.b are met. The individual designated to be continuously available to close the air lock door must be stationed at the auxiliary building side of the air lock. A containment personnel air lock door is considered capable of being closed if the door is not blocked in such a way that it cannot be expeditiously closed, and any hoses and cables running through the air lock employ a means to allow safe, quick disconnect or severance, and are tagged at the air lock with specific instructions to expedite removal. The LCO 3.9.10 requirement to maintain a minimum of 23 feet of water over the top of irradiated fuel assemblies seated within the reactor pressure vessel during movement of fuel assemblies within the reactor pressure vessel while in MODE 6 ensures that sufficient water depth is available to remove 99% of the assumed iodine gap activity released from the rupture of an irradiated fuel assembly.

Further, sufficient time is available to close the personnel air lock following a loss of shutdown cooling before boiling occurs.

DAVIS-BESSE, UNIT 1 B 3/4 9-1 Amendment No. 15,202,207 Revised by NRC letter dated March 19, 1998

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