Text

Response to NRC Request for Additional Information Regarding Generic Letter 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems.
	ML093020224
Person / Time
Site:	Davis Besse
Issue date:	10/26/2009
From:	Allen B; FirstEnergy Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-08-001, L-09-263, TAC MD7819
	Download: ML093020224 (14)
	v • d • e

FENOC 00-% 5501 North State Route 2 FirstEnergyNuclear OperatingCompany Oak Harbor,Ohio 43449 Barry S. Allen 419-321-7676 Vice President- Nuclear Fax: 419-321-7582' October 26, 2009 L-09-263 10 CFR 50.54(f)

ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Response to NRC Request for Additional Information Regarding Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" (TAC No. MD7819)

In a letter dated August 26, 2009, the Nuclear Regulatory Commission (NRC) provided a request for additional information (RAI) related to Generic Letter (GL) 2008-01 for the Davis-Besse Nuclear Power Station (DBNPS). Previous FirstEnergy Nuclear Operating Company correspondence responding to GL 2008-01 for DBNPS was provided in letters dated April 11, 2008 (L-08-132) and October 14, 2008 (L-08-314). The response to the RAI is provided in Attachment 1.

The regulatory commitment identified in Attachment 2 supersedes a commitment made in the letter dated October 14, 2008. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager -

Fleet Licensing, at (330) 761-6071.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October '24', 2009.

Sincerely, Barry S. Allen Attachments:

1. Response to NRC RAI on Generic Letter 2008-01 for DBNPS

2. Regulatory Commitment List cc: NRC Region III Administrator NRC Resident Inspector NRC Project Manager /KA Utility Radiological Safety Board

Attachment 1 L-09-263 Response to NRC RAI on Generic Letter 2008-01 for DBNPS Page 1 of 12 This attachment provides the FirstEnergy Nuclear Operating Company (FENOC) response to the Request for Additional Information (RAI) from the Nuclear Regulatory Commission (NRC) staff regarding the Davis-Besse Nuclear Power Station (DBNPS) response to Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems." The NRC staff requests are presented below in bold type, followed by the FENOC response. In the following NRC staff requests, "Reference 4" is referring to the nine month response to GL 2008-01 for DBNPS, dated October 14, 2008 (Agencywide Documents Access and Management System [ADAMS] Accession No. ML082900577).

1: GL 08-01 discussed the loss of high-pressure safety injection pumps at Oconee in 1997, as an example of failure of a subject system. This was caused by a failure of level transmitters associated with the letdown storage tank that is commonly referred to as the volume control tank (VCT). The VCT was not identified in the Reference 4 reply to the GL. Either identify the VCT as a part of the subject systems, or provide a justification for its omission.

Response

The DBNPS Makeup (MU) Tank (similar to a Volume Control Tank) is not within the scope of GL 2008-01. The MU Tank does not provide a suction source of water for the subject Emergency Core Cooling Systems, Decay Heat System, or Containment Spray System. The DBNPS MU Tank serves the Makeup and Purification System, which provides the normal reactor coolant system makeup and purification function [reference Updated Safety Analysis Report (USAR) Sections 9.3.4 and 6.3.1.1].

The High Pressure Injection (HPI) pumps at Oconee perform dual functions of reactor coolant system makeup and high-pressure safety injection. The Oconee HPI pumps normally take suction from the letdown storage tank (also referred to as the makeup or volume control tank by other vendors - reference NRC Information Notice 97-38, "Level-Sensing System Initiates Common-Mode Failure of High-Pressure-Injection Pumps").

In contrast, the DBNPS HPI pumps do not perform the dual functions of reactor coolant system (RCS) makeup and high pressure injection. The DBNPS HPI system provides high pressure injection, taking suction from the Borated Water Storage Tank (BWST) during the post-Loss of Coolant Accident (LOCA) initial injection phase, and later transferring suction to the Containment Emergency Sump, via the decay heat removal pumps discharge, when approaching depletion of the BWST. The BWST and associated BWST level instrumentation were evaluated as part of the GL 08-01 subject systems and were determined to not be vulnerable to the referenced Oconee transmitter failure mechanism because the BWST level instrumentation does not share L-09-263 Page 2 of 12 a common wet reference leg. The interconnections between the makeup system and the HPI and Decay Heat (DH) systems were reviewed as part of the GL 08-01 evaluations for the potential to introduce gas into the GL 2008-01 systems.

2: Provide a schedule and commitment for applying the Technical Specification Task Force process to any Technical Specifications (TS) modifications related to GL 08-01.

Response

The regulatory commitment regarding evaluation of industry-developed generic Technical Specification (TS) changes that was included in the nine month response is being revised. The following commitment supersedes the previous commitment in its entirety:

FirstEnergy Nuclear Operating Company (FENOC) is continuing to support the industry Gas Accumulation Management Team (GAT) and Technical Specification Task Force (TSTF) activities regarding the resolution of generic Technical Specifications changes via the TSTF Traveler process.

Within 180 days after NRC approval of the Traveler, FENOC will complete an evaluation and determine whether to adopt the Traveler at DBNPS.

3: Summarize the corrective action program results that were initiated to develop a design calculation to address vortex formation for the decay heat removal pumps during suction from the reactor coolant system hot-legs.

Response

This corrective action was included as Item number 2 in Table 2 of the nine month response, which identified enhancement items. This is considered an enhancement item because review of the applicable procedures for operation of the DH System during shutdown, combined with previous operating experience in such configurations, identified that adequate precautions exist for maintaining DH pump suction from the reactor. The curves provided to the plant operators showing DH flow limits versus reactor vessel water level are based on actual tests performed during startup testing.

Implementation of this corrective action will be addressed in three phases. Prior to the next refueling outage (1 R1 6), scheduled for the first quarter of 2010, the curves provided to the plant operators will be revised to incorporate instrument uncertainty values that are currently available in existing plant calculations. During 1 R1 6, additional DH system performance data will be obtained in order to validate the model to be used in the design calculation. The design calculation is scheduled to be completed within four months following 1 R1 6; when complete, it will be available for review onsite.

L-09-263 Page 3 of 12 4: An evaluation of vortex formation was stated to have concluded that maximum flow scenarios during design basis actuations did not have the potential for adverse gas intrusion since the void fraction would be less than 2 percent. Since expected flow rates under accident conditions may significantly exceed the design-basis accident (DBA) flow rates, discuss how the stated conclusions are applicable to actual expected accident conditions.

Response

It is recognized that in performing evaluations of vortex formation, it is conservative to maximize the assumed flow rate being drawn from the suction source. It is also recognized that actual post-accident plant response might result in much higher flow rates being drawn from such a suction source than the flow rates classically assumed in design-basis accident (DBA) analyses. This is because DBA analyses typically assume a single failure of a diesel-generator that in turn results in half of the installed pumps not responding, and less than maximum flow rates from the systems.

With respect to suction from the Borated Water Storage Tank (BWST), the above issues were appropriately addressed in the existing DBNPS vortex formation calculation that concluded the void fraction would be less than two percent. The calculation assumes bounding system flow rates during a maximum flow scenario in which both trains of the Emergency Core Cooling Systems (ECCS) and the Containment Spray (CS) systems respond and take suction from the BWST concurrently, as level is lowered to the transfer point and as suction is switched over to the emergency sump.

The vortex calculation conclusions are therefore applicable to actual expected accident conditions.

With respect to suction from the containment emergency sump, information was provided in Section A.2a of the nine month response explaining why vortex formation in the emergency sump, after the transfer is complete, is not a concern.

5: Table 2 of Reference 4 lists quarterly monitoring items. Have these been implemented? What is the justification for quarterly monitoring in light of the general industry surveillance requirement of 30 days?

Response

The quarterly monitoring items, listed in Table 2 of Reference 4, have been implemented. The quarterly monitoring tasks are performed by preventive maintenance (PM) activities using the Work Management Process.

The quarterly monitoring frequencies were determined to be appropriate based on gas intrusion assessments, which applied a graded approach to establish periodic ultrasonic testing (UT) verification frequencies. The graded approach utilized in these qualitative assessments included consideration of the underlying gas intrusion mechanisms, L-09-263 Page 4 of 12 relative differential pressure across the barrier, and the potential impact of gas accumulation in various piping segments. For example, potential pump suction piping void locations were generally assigned a monthly monitoring frequency because of the potentially significant impact of a void on pump performance, whereas potential pump discharge piping void locations were generally assigned a quarterly monitoring frequency due to the lesser impact of a discharge piping void. The quarterly monitoring frequencies were concluded to be appropriate for the referenced piping locations.

This approach of determining an appropriate frequency for specific portions of piping is consistent with industry plans to manage gas accumulation by permitting adjustment of monitoring frequencies rather than using an inflexible frequency for all piping segments.

6: The TS surveillance requirement addresses high point venting of the discharge piping on a one time post-maintenance vent. Additional venting is stated to be performed by periodic procedure DB-SP-04212, "Venting of ECCS Piping - SOER 97-1." Summarize this and any other procedures that address surveillance with respect to specific venting frequency, method of determining void volumes, maintenance of void volume records, acceptance criteria, and follow-up actions if acceptance criteria are not met. If this procedure update is not complete, identify the incomplete items and provide a schedule for completion. Where the monitoring is to be accomplished via the work management process, provide the same information and, in addition, describe what ensures acceptable follow-up if voids are identified. Note that "periodic" and "appropriate periodic" are not specific with respect to this request for additional information.

Response

Procedure DB-SP-4212 was revised in June 2009 to change its focus to performance of UT of associated piping locations as the means of detection of voiding, rather than venting. This procedure currently requires UT verifications at a total of 37 locations, including locations on both the suction and the discharge sides of the GL 08-01 systems. DB-SP-04212 is performed following plant startups from refueling outages and other MODE 5 shutdowns.

To supplement this procedure, quarterly and monthly preventive maintenance (PM) verifications have also been implemented. The quarterly PM UT activities address 20 locations, primarily on the discharge sides of the systems, including the seven quarterly ultrasonic tests that were listed in the corrective actions contained in Table 2, Item number 4 of the DBNPS nine month response. The monthly PM UT verifications address 26 locations, primarily on the suction sides of the systems. These PM UT verifications are performed more frequently than the checks performed by procedure DB-SP-4212. After performance of the ultrasonic tests per either DB-SP-04212 or the PM activities, venting is performed as determined necessary based on the UT results.

L-09-263 Page 5 of 12 The UT verifications performed per DB-SP-04212 and those performed per the referenced PM activities allow for the quantification of potential voids. DB-SP-04212 requires that a Condition Report be initiated if other than water-solid conditions are detected during the performance of the UT verifications. Similarly, the referenced monthly and quarterly PM activities each include a step that requires that a Condition Report be initiated if a new void location is detected. Therefore the Corrective Action Program is entered if a void is detected by the various UT activities. The Corrective Action Program documentation provides maintenance of void volume records and documentation of the appropriate follow up actions.

The TS venting surveillance requirement discussed in request number 6 is implemented by procedure DB-SP-03212, "Venting of ECCS Piping." DB-SP-03212, which is performed during startups from refueling outages and after activities that drain the ECCS piping, is scheduled to be revised prior to the next refueling outage (scheduled for the first quarter of 2010) to require UT verifications at the specified venting locations prior to performing the Technical Specification Surveillance Requirement venting activity. Because normal post-maintenance fill and vent activities performed subsequent to draining of an ECCS system should be sufficient to restore a water-solid condition, DB-SP-03212 will also be revised to require that if other than water-solid conditions are detected during the UT verification, a CR must be initiated. This revision is scheduled for the first quarter of 2010.

7: The statement is made that "the surveillance and periodic testing procedures DB-SP-03212, "Venting of ECCS Piping," and DB-SP-04212 require that a Condition Report be generated if gas voiding concerns are identified." Clarify this statement with respect to the meaning of a gas voiding concern. If the Corrective Action Program is not entered whenever a void is identified during operation, then provide a justification why this is not accomplished.

Response

At the time of the nine month GL response, procedures DB-SP-03212 and DB-SP-04212 included the referenced guidance to generate a Condition Report if "gas voiding concerns" were identified. This guidance was intended to require entering the Corrective Action Program if conditions were observed during the venting process that were indicative of a voiding concern, rather than for the presence of residual air trapped in the vent valve outlet pipe stub or coming from the hose connections. Recognizing the potential subjectivity associated with such an observation during a venting task, the method of performing periodic checks has been shifted to monitoring the associated piping locations for voiding using UT verification techniques. Consequently, DB-SP-04212 (which is performed following plant startups from refueling outages and other MODE 5 shutdowns) has been revised to perform the referenced UT verifications.

L-09-263 Page 6 of 12 The criterion for generation of a Condition Report (CR) is now clear - a CR is written if water-solid conditions are not found during the UT. Venting is performed if that is the corrective action determined by the corrective action program.

As discussed above in request number 6, DB-SP-03212 is being revised to include UT verifications, with a requirement that the piping must be water-solid or a CR must be written.

Therefore, the Corrective Action Program will be entered when a void is identified through performance of either procedure DB-SP-04212 or DB-SP-03212.

Furthermore, the additional monthly and quarterly PM UT verifications at selected piping locations (as discussed in other RAI responses), include steps that require initiation of a CR if other than water-solid conditions are detected.

8: Summarize the procedural checks to periodically identify leakage through check valves that separate the subject systems from higher pressure locations and the response actions in procedures and the Corrective Action Plan if such leakage is identified. Include in-series check valves that could be exposed to a higher pressure if the "first off' check valves were to leak.

Response

High Pressure Iniection System The HPI system has three "in series" leak-tested check valves in each pathway between the higher-pressure reactor coolant system and the HPI pumps. The first two (inboard) valves in each pathway to the RCS are tested as a "back to back" pair, as required by a Toledo Edison letter dated June 30, 1987 (Serial number 1392), "Response to Generic Letter 87-06, Periodic Verification of Leak Integrity of Pressure Isolation Valves," and the Inservice Test Program. The test is performed at approximately full RCS pressure conditions once per refueling cycle. Initiation of a Condition Report is required if leakage exists. Therefore, the Corrective Action Program is entered if back-leakage is detected.

The next leak-tested valve located in each injection pathway upstream (outboard) of the "back to back" check valves is the HPI Pump Discharge Check Valves. Leak testing is performed approximately every 24 months. A Condition Report is required to be written if leakage exceeds the acceptance criterion.

Core Flooding Tanks There are two "in series" leak-tested check valves in each pathway between the higher-pressure RCS and the Core Flooding Tanks. Leakage past each check valve is individually measured once every refueling interval. If leakage is detected past either valve in the pathways to the Core Flooding Tanks, then the procedure requires evaluation of the potential effects of the back-leakage. Procedure changes are L-09-263 Page 7 of 12 scheduled to be complete prior to next use (1R16), to require initiation of a Condition Report if such leakage is detected. This will ensure the Corrective Action Program is entered when back-leakage is identified.

Decay Heat Removal/Low Pressure Injection In the piping pathways between the higher-pressure RCS and the Decay Heat Removal (DHR)/Low Pressure Injection (LPI) trains are two "in series" check valves.

The inboard valve in each of these pathways is common to the Core Flooding Tank piping that leads to the RCS, and therefore its individual leak test has already been discussed above in the Core Flooding Tank discussion. The other (outboard) check valve in the DH/LPI pathway to the RCS is also leak tested individually once every refueling interval. If leakage is detected, then the procedure requires evaluation of the potential effects of the back-leakage. Procedure changes are scheduled to be complete prior to next use (1 R1 6), to require initiation of a Condition Report if such leakage is detected.

In the piping pathways between the higher-pressure Core Flooding Tanks and the DH/LPI trains there is one leak-tested valve, which is the second (outboard) valve discussed in the paragraph above, with a leak check performed each refueling interval.

Additionally, a new procedure was implemented in December 2008 to perform weekly monitoring of the Core Flooding Tank level trends, and also review the CFT water addition history (e.g. the last three CFT water additions). A Condition Report is initiated if an unexplained decreasing CFT level trend is observed.

There are several other check valves located in the DH System discharge piping that could experience a higher pressure if the single valve separating each DH train from its Core Flooding Tank was to leak. First, a check valve in each DH pump suction from the BWST is closure tested in accordance with Inservice Test Program requirements by demonstrating the ability to establish differential pressure across the valve. A Condition Report must be written if this test is not acceptable. Second, there are two pairs of check valves installed in a line that cross-connects the two DH trains at the coolers (heat exchangers). Each pair of check valves are closure tested, as a pair, in accordance with Inservice Test Program requirements, by demonstrating no rapid pressure increase in the upstream pressure. A Condition Report must be written if this test is not acceptable. Finally, the DH Pump discharge check valve in each train could be exposed to a higher pressure if leakage occurred past the "first off check valve, however, that increased pressure downstream of the pump discharge valve would also be applied to its upstream side due to a bypass flowpath around the valves provided by the DH Pump minimum recirculation piping. These discharge check valves are tested approximately every four years in accordance with Inservice Test Program requirements by performing a periodic sample disassembly examination. A Condition Report must also be written if the results of this examination are not acceptable.

L-09-263 Page 8 of 12 The requirement to initiate Condition Reports for each of the above described tests ensures the Corrective Action Program is entered when test acceptance criteria are not met.

Core Flooding Tank Common Fill Piping In the piping used to periodically add water (from the HPI system) and nitrogen (from the Nitrogen Supply System) to the Core Flooding Tanks during normal operation, there are two individually leak-tested valves in each train. The valve closer to the Core Flooding Tank is a check valve, with the next upstream (outboard) valve being a normally closed air operated globe valve. Reverse leakage past each of these valves (toward the fill systems) is individually checked in accordance with Appendix J requirements. A Condition Report is written if leakage exceeds the acceptance criterion.

Because the HPI and the Nitrogen Supply System both connect to the common fill line that leads to the Core Flooding Tank in each train, there is an interface between the Nitrogen Supply System and the HPI system that is separated by a normally closed, manual gate valve. The HPI piping upstream (on the side away from the Nitrogen Supply System) of this valve in each train is monitored monthly for potential nitrogen back-leakage, using UT. Specifically, a monthly Preventive Maintenance (PM) task performs UT verification on the HPI Train fill piping upstream (outboard) of the normally closed boundary valve. If the PM UT verification detects a piping void, the PM requires immediate notification of the Operations Shift Manager and requires the initiation of a Condition Report.

9: With respect to Section C, "Additional Planned Actions," Table 2, of Reference 4, the statement is made that "...current practices have been determined to be effective at preventing equipment damage caused by voids, and these actions are not required for compliance with existing regulatory requirements..." Clarify this statement since operability, not damage, is a compliance requirement. Clarify the "existing regulatory requirements" with respect to the GL requirement that information be provided for all conditions and all modes of operation, not just DBAs or power operation.

Response

For the first part of RAI request number 9, the paragraph introducing TABLE 2 below has been revised to more appropriately state that the listed items are enhancement items because "...current practices have been determined to be effective at maintaining system operability with respect to voids...".

For the second portion of the question, the paragraph introducing TABLE 2 has been revised to clarify the statement about existing regulatory requirements by stating that L-09-263 Page 9 of 12 "none of these actions are required for compliance with the regulatory requirements discussed in GL 2008-01 ." As noted in the response to RAI request number 4, it is recognized that management of gas within the subject systems must address conditions other than just DBA conditions, and, as in the case of Decay Heat, must also address modes of operation other than just power operation.

10: Provide a table that lists the current incomplete items and the completion schedule.

Response

Necessary actions to achieve full compliance with the regulations were listed in Table 1 of the nine month response. Of the 11 items, 10 have been completed. The one ongoing item is summarized below.

INCOMPLETE TABLE 1 ITEMS

1. Summary: DB designs do not incorporate a pipe slope to ensure proper fill and vent by static methods. Current processes/procedures also do not incorporate dynamic flushing. Revise processes/procedures as appropriate to incorporate dynamic flushing.

Current Status: In the interim period until additional industry guidance on gas management is published and considered, a combination of ultrasonic testing (UT),

venting, and dynamic flushing is being performed to ensure a proper fill and vent. The incorporation of industry guidance, as appropriate, is expected to be completed during the next operating cycle (Cycle 17).

Enhancement actions were listed in Table 2 of the nine month response. Those items were recommended to improve management of gas accumulation at DBNPS. Because current practices were determined to be effective at maintaining system operability with respect to voids, and none of these actions were required for compliance with the regulatory requirements discussed in GL 2008-01, the actions were identified as enhancements. If part of a Table 2 item remains incomplete, it is summarized below.

The schedule for completion of each remaining enhancement item, along with follow-up activities identified during closure of any Table 2 item, is based on resource and plant availability, and the actions are managed in accordance with the FENOC Corrective Action Program or other appropriate action tracking mechanisms.

INCOMPLETE TABLE 2 ENHANCEMENT ITEMS AcNti'ons Identified During the Section 1 Licensing Basis Evaluation

1. Summary: Track USAR changes to incorporate information describing performance-based periodic checks, and to more clearly reflect the concept that gas accumulation occurs, but is managed.

Current Status: As noted in Section 1a of the nine month response, this item is L-09-263 Page 10 of 12 1 scheduled for completion 120 days following NRC closure of the GL 2008-01 review.

Actions lde'tified Duriingthe Sectionh2a Design BasisDocument Reviewi* ,,

2. Summary: Track development of a design calculation to address vortexing and NPSH for Decay Heat pumps during suction from the reactor.

Current Status: See RAI item No. 3 discussion. Currently scheduled for November 2009.

Actions Identified During the Section 2e *Gas . ntusion

..- Review,

4. Summary: Track enhancements identified, including procedure revisions and UT monitoring. The enhancements are summarized below:

A. Quarterly UT Monitoring Actions 1 through 7.

Current Status: Complete.

B. Procedure Enhancements Items B.1, B.8, B.10, B.11, B.12, & B.13: Misc. enhancements to DB-OP-06012, "Decay Heat and Low Pressure Injection System Operating Procedure" Current Status: Scheduled for completion during the next operating cycle (Cycle 17).

Items B.2, B.6, & B.7: Miscellaneous enhancements to DB-OP-06021, "Spent Fuel Pool Operating Procedure" Current Status: Scheduled for completion during the next operating cycle.

Item B.3: Enhancement to DB-OP-0601 1, "High Pressure Injection System" Current Status: Complete.

Items B.4, B.5, and B.9: Miscellaneous enhancements originally planned to go into DB-OP-06021, "Spent Fuel Pool Operating Procedure" (items B.4 &

B.5) or DB- OP-6006, "MU Operating Procedure" (item B.9)

Current Status: DB-OP-06012 was determined to be the appropriate procedure to be revised. Scheduled for completion during the next operating cycle.

Item B.14: Enhancement to DB-OP-06013, "Containment Spray System" Current Status: Complete.

Item B.15: Enhancement to-DB-SP-03304, "Containment Spray System Nozzle Check (Lower Header)," and DB SP 03305, " Containment Spray System Nozzle Check (Upper Header)"

Current Status: To be revised prior to next use.

Item B.16: Enhancement to DB-OP-06006, "Makeup and Purification System" Current Status: Scheduled for completion during the next operating cycle.

C. Monitoring enhancements following plant startup from a plant shutdown to MODE 5 Item C.1: Enhancement to DB-SP-04212, "Venting of ECCS Piping - SOER 97-1" Current Status: Complete.

L-09-263 Page 11 of 12 Item C.2: Enhancement to procedures DB-SP-03337 "CS Train 1 Quarterly Pump and Valve Test," DB-SP-03338, "CS Train 2 Quarterly Pump and Valve Test," DB-SP-03218, "HPI Train 1 Pump and Valve Test," DB-SP-03219, "HPI Train 2 Pump and Valve Test," DB-SP-03136, "DH Train 1 Pump and Valve Test," and DB-SP-03137, "DH Train 2 Pump and Valve Test" Current Status: Five of the six procedures are revised. DB-SP-03338 is scheduled for completion during the next operating cycle.

Item C.3: Enhancement to DB-OP-06012, "Decay Heat and Low Pressure Injection System Operating Procedure" Current Status: Scheduled for completion during the next operating cycle.

D. Miscellaneous Enhancement Actions:

Items D.1 & D.2: Evaluate installation of a new check valve in the MU Pump 1 & 2 suction piping from the BWST to prevent reverse flow from the MU system into the BWST/HPI pump suction piping.

Current Status: Evaluations scheduled for completion in December 2009.

Actions Identified During the Section 2g System In-Field Verification Review

7. Summary: Complete nine Containment and Annulus piping in-field verifications during the next refueling outage (1R16).

Current Status: To be performed in 1R16, which is scheduled to begin in the first quarter of 2010.

8. Summary: Track a design engineering review of the piping in-field verifications.

Based on results, initiate additional follow-up items as appropriate.

Current Status: Additional verifications and engineering reviews are associated with 1R16. This item is scheduled for completion by June 2010.

Actions IdentifiedDurinnthe Section 3 Testing Evaluation

9. Summary: Evaluate and track potential enhancements identified during review of the following testing/surveillance procedures.

1. DB-PF-0301 1, "ECCS Integrated Train 1 Leakage Test" Revise in Cycle 17

2. DB-PF-03012, "ECCS Integrated Train 2 Leakage Test" Revise in Cycle 17

3. DB-PF-03068, "Check Valve Forward Flow Tests" Revise in Cycle 17

4. DB-PF-03069, "Check Valve Closure & Leakage Tests" Revise in Cycle 17

5. DB-PF-04167, "Power Operated Valve D/P & Flow Test" Revise in Cycle 17

6. DB-SP-03302, "CF28 & CF29 Leak Test" Complete

7. DB-SP-03337, "CS Train 1 Quarterly Pump & Valve Test" Complete

8. DB-SP-03338, "CS Train 2 Quarterly Pump & Valve Test" Revise in Cycle 17

9. DB-SP-03136, "DH Train 1 Pump & Valve Test" Complete

10. DB-SP-03137, "DH Train 2 Pump & Valve Test". Complete

11. DB-PF-03236, "DH Pump 1 Baseline Test" Complete

12. DB-PF-03237, "DH Pump 2 Baseline Test" Complete Current Status: See information to the right of each item.

L-09-263 Page 12 of 12 Ation Sidnified During the Section4 Co rrectiveAction Program valuation

10. Summary: Develop design change package for installation of vent valves on both DH pump minimum recirculating lines.

Current Status: The design change package is scheduled for issuance in February 2010.

The FENOC corrective action program described in Section A.4 of the nine month response addresses on an ongoing basis other corrective actions related to potential gas accumulation within GL 2008-01 subject systems.

11: Training was not identified in the GL, but is considered to be a necessary part of applying procedures and other activities when addressing the issues identified in the GL. Briefly discuss training as it relates to both venting and the procedures.

Response

DBNPS training addressing gas accumulation issues identified in NRC and industry documents such as Significant Operating Experience Report [SOER] 97-01 and Significant Event Report [SER] 2-05, is an ongoing topic, as directed by the associated training curriculum review committees. Training on these topics for licensed and non-licensed operators occurred in 2007 and 2008, for Engineering staff in 2009, and for Instrumentation and Controls technicians in 2007.

An industry-developed computer based training module addressing GL 2008-01 issues is scheduled to be reviewed, revised if appropriate, and completed by Engineering and Operations personnel prior to 1 R16.

As procedures related to gas management are updated, the procedure revision process determines whether a formal training needs analysis should be performed. Procedures that are implemented in a step-by-step fashion, in which the procedure is in hand directing the actions, do not typically require formal training. For other types of procedures, the established procedure review/approval and change management processes address the need for personnel awareness or training on the revisions.

Monitoring of industry-sponsored gas accumulation training recommendations continues, since such input presents the opportunity to incorporate appropriate training into associated accredited training programs.

Attachment 2 L-09-263 Regulatory Commitment List Page 1 of 1 The following list identifies one revised Regulatory Commitment for the Davis-Besse Nuclear Power Station. The original commitment was made in the nine month response to Generic Letter 2008-01, dated October 14, 2008 (L-08-314). Any other actions discussed in this submittal represent intended or planned actions, are described only for information, and are not Regulatory Commitments. Please notify Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 761-6071 of any questions regarding this document or associated Regulatory Commitments.

Revised Requlatory Commitment FirstEnergy Nuclear Operating Company (FENOC) is continuing to support the industry Gas Accumulation Management Team (GAT) and Technical Specification Task Force (TSTF) activities regarding the resolution of generic Technical Specifications changes via the TSTF Traveler process. Within 180 days after NRC approval of the Traveler, FENOC will complete an evaluation and determine whether to adopt the Traveler at DBNPS.