L-13-341, Review of the Safety Evaluation Report Related to the License Renewal of Davis-Besse Nuclear Power Station

Review of the Safety Evaluation Report Related to the License Renewal of Davis-Besse Nuclear Power Station

ML13294A463
Person / Time
Site:	Davis Besse
Issue date:	10/18/2013
From:	Lieb R FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-13-341, TAC ME4640
Download: ML13294A463 (6)

Text

FENOCm 5501 North State Route 2 Oak Harbor, Ohio 43449 FIrstEnergyNuclear OperatingCompany Raymond A. Lieb 419-321-7676 Vice President, Nuclear Fax: 419-321-7582 October 18, 2013 L-13-341 10 CFR 54 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 Review of the Safety Evaluation Report Related to the License Renewal of Davis-Besse Nuclear Power Station (TAC No. ME4640)

By letter dated August 27, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML102450565), FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse). By letter dated September 3, 2013 (ML13172A015), the Nuclear Regulatory Commission (NRC) issued the "Safety Evaluation Report Related to the License Renewal of the Davis-Besse Nuclear Power Station" (SER) and requested that FENOC review the SER and provide comments to the staff.

FENOC has completed its review of the SER. The Enclosure provides FENOC comments on the SER.

There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

Sincerely, Rayr'nd A. Lieb

Davis-Besse Nuclear Power Station, Unit No. 1 L-13-341 Page 2

Enclosure:

Comments Related to Safety Evaluation Report Related to the License Renewal of Davis-Besse Nuclear Power Station cc: NRC DLR Project Manager NRC Region III Administrator cc: w/o Enclosure NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board

Enclosure Davis-Besse Nuclear Power Station, Unit No. 1 (Davis-Besse)

Letter L-13-341 Comments Related to Safety Evaluation Report Related to the License Renewal of Davis-Besse Nuclear Power Station 3 pages follow

FirstEnergy Nuclear Operating Company (FENOC) Comments Related to "Safety Evaluation Report Related to the License Renewal of Davis-Besse Nuclear Power Station" [SER]

L-1 3-341 Page 1 of 3 Item SER Section SER Page Comment No.

Abbreviations xix The abbreviation "RT" is listed as "radiological testing" but should read "radiographic testing".

2 1.7 1-10 In the middle of the third paragraph, the sentence that begins, "In response to RAI A4-1 Part (2)...", should read "In response to RAI A. 1-1 Part(2)...".

3 2.3.3.12.2 2-53 The third paragraph should refer to RAI 2.3.3.12-01, not 2.3.3.11-03.

4 Table 3.0-1 3-7 At the top of the page, the 10 CFR Part 50, Appendix J Program, should be identified as "Consistent with enhancement" based on the enhancement added with Commitment 27 by FENOC letter L-1 1-134 dated May 5, 2011 (ML11131A073).

Table 3.0-1 3-9 At the top of the page, the Inservice Inspection (ISI)

Program-IWF should be identified as "Consistent with enhancements" based on the enhancements added with Commitment 50 by FENOC letters L-13-181 dated May 17, 2013 (ML13141A271) and L-13-199 dated June 4, 2013 (ML13158A302).

Table 3.0-1 3-9 The PWR Reactor Vessel Internals Program should be identified as "Consistent" with GALL Rev. 2 based on the response to RAI B.2.32-1 provided by FENOC letter L-11-252 dated September 16, 2011 (ML11264A059).

FENOC Comments Related to SER L-13-341 Page 2 of 3 Comment 3.0.3.2.15 This comment addresses wording that could cause Structures confusion. The third paragraph states that FENOC letter Monitoring L-12-455 dated January 21, 2013 (ML13023A113),

Program "updated the 'preventive actions' and 'detection of aging effects' program elements to include volumetric inspections of high-strength structural bolts."

However, the volumetric inspections are not included in the 'preventive actions' program element. Although L-1 2-455 (Enclosure, Page 5 of 5) updated the 'preventive actions' program element, the update relates to preventing future use of high strength bolting and not volumetric inspections, as is described in the next SER sentence on SER Page 3-158, which associates the update with Commitment No. 20, not with a program element.

8 3.0.3.3.9 3-249 The following typographical error could have a technical Shield aspect. The first line on Page 3-249 begins: "... with ACI Building 34.3R, an appropriate industry guidance document...".

Monitoring The referenced ACI document should include a "9", as in Program "349.3R". This ACI document is referenced by the correct number many times in this section of the SER, so the possibility of technical confusion is minimal.

3.0.3.3.9 3-252 The third paragraph of the Monitoring and Trending Shield (Monitoring program element includes the phrase: "... in accordance Building and with industry standards, specifically ACI 349.3R.

Monitoring Trending However, as noted in the April 5, 2002, NRC letter to NEI Program Element) (ML020980194, page 2), ACI 349.3R is a report, not a standard.

In the SER with Open Items, ACI 349.3R was referred to as a standard. In response to a FENOC comment on that topic, the Final SER was corrected to refer to ACI 349.3R as a guideline or guidance (e.g., see Item No. 8 above).

On the same SER page (3-252) in the first paragraph of the review of the Acceptance Criteria, ACI 349.3R is described as "ACI Report 349.3R", as it is in other SER locations. Also, many additional references (about 60) to ACI 349.3R in the Final SER avoid stating that the report is a code or standard.

FENOC Comments Related to SER L-1 3-341 Page 3 of 3 Item SER Section SER Page Comment No.

10 4.3.2.3.2 4-68 This section is applicable to Class 1 piping only and therefore the reference to "OTSGs" should be deleted and "piping" inserted in the following sentence (starting at the bottom of SER Page 4-67 and ending at the top of Page 4-68):

"The staff reviewed the CUF values provided by the applicant, in Table 3-7 of AREVA Document 51-9157140-001, in response to RAI 4.3-12 (letter dated June 17, 2011), and confirmed that the design CUF values for the Class 1 comp.nents a. . ciatd with the QT-SGs 2pign are less than the design limit of 1.0."

11 Appendix B B-9 FENOC letter L-12-262 (Annual Update) dated August 9, Chronology 2012 (ML12229A139), is not listed in the Chronology.

B-10 FENOC letter L-12-418 dated November 20, 2012 (ML12331A125), is not listed in the Chronology.

FENOC letter L-12-432 dated December 20, 2012 (ML12361A255), is not listed in the Chronology.

B-1 1 Item dated May 17, 2013 includes "ML" twice in the parenthetical reference (Accession No.

MLML13141A271).

Item dated July 9, 2013 includes the year but not the date of the telecon... the telecon was held on May 9, 2013.