ML022400295

Draft Ltr from s Sands, NRR to G Campbell, Regarding Davis Besse Documentation of Conference Call of November 15, 2001 Concerning Response to Bulletin 2001-01

ML022400295
Person / Time
Site:	Davis Besse
Issue date:	08/27/2002
From:	Sands S NRC/NRR/DLPM
To:	Campbell G FirstEnergy Nuclear Operating Co
References
BL-01-001, FOIA/PA-2002-0229, TAC MB2626
Download: ML022400295 (4)

Text

""U E UNITED STATES NUCLEAR REGULATORY COMMISSION 0 WASHINGTON, D.C. 20555-0001 Mr. Guy G. Campbell, Vice President - Nuclear FirstEnergy Nuclear Operating Company 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - DOCUMENTATION OF CONFERENCE CALL OF NOVEMBER 15,2001, RE: RESPONSE TO BULLETIN 2001-01 (TAC NO. MB2626)

Dear Mr. Campbell:

On November 15, 2001, a conference call was held between the staff and representatives of FirstEnergy Nuclear Operating Company concerning the staff's assessment of the Davis-Besse response to Nuclear Regulatory Commission (NRC) Bulletin 2001-01, "Circumferential Cracking of Reactor Pressure Vessel Head Penetration Nozzles." This conference call reflected recent meetings held with your staff at the NRC offices in Rockville, MD, on November 8, 9, and 14, 2001. The purpose of this letter is to document the staff's findings as discussed during the conference call.

As discussed in the bulletin, the Davis-Besse facility is considered to have a high susceptibility to primary water stress corrosion cracking (PWSCC) at reactor pressure vessel head penetration (VHP) nozzles. Thirteen reactor facilities have been categorized as having a high susceptibility to PWSCC at the VHP nozzles. To date, eleven of these facilities have performed inspections as recommended in the bulletin and ten of these have identified cracking in VHP nozzles. With respect to the seven operating Babcock and Wilcox (B&W) facilities, the other six facilties (Davis-Besse excluded) have performed inspections as recommended in the bulletin and all six facilities have identified cracking in VHP nozzles. More significantly, three of these B&W facilities have identified circumferential cracking.

The staff believes there is a reasonable likelihood that the Davis-Besse facility currently has multiple cracks in the VHP nozzles and that one or more of these cracks could be circumferential. The staff has viewed the photographs provided of the Davis-Besse reactor vessel head and videotapes taken from previous refueling outages and is unable to make an independent assessment of the structural integrity of the VHP nozzles.

During the conference call, your staff asked how the NRC had factored the probabilistic safety assessment (PSA) included in your submittal of November 1, 2001. The staff has reviewed the risk assessment included in your submittal and finds the methodology employed to be reasonable. However, the inspection credits for the 1996, 1998, and 2000 inspections and the probabilistic fracture mechanics on crack initiation-propagation are unresolved due to inadequate data and ambiguity to support the risk numbers presented in your submittal.

Based on our review of the information you have provided in your bulletin responses (which includes the staff's request for additional information), the videotapes from previous outages, the PSA included in your submittal of November 1, 2001, and the information provided in the

G. Campbell meetings identified above, the staff is unable to reconcile the inspection results described above. The staff has not identified any mitigating factors which would distinguish Davis-Besse from the other high susceptible facilities that have previously shut down and identified cracking in the VHP nozzles.

As discussed in the conference call, the staff does not envision a success path using traditional analyses or risk arguments. The staff believes that based on the information available, inspections as recommended in the bulletin are the only means to provide reasonable assurance of the structural integrity of the reactor vessel head. Therefore, any future discussions or submittals on this subject should focus on how Davis-Besse is unique or can be distinguished from the inspection results from the other, high susceptible facilities.

Sincerely, Stephen P. Sands, Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-346 cc: See next page

G. Campbell meetings identified above, the staff is unable to reconcile the inspection results described above. The staff has not identified any mitigating factors which would distinguish Davis-Besse from the other high susceptible facilities that have previously shut down and identified cracking in the VHP nozzles.

As discussed in the conference call, the staff does not envision a success path using traditional analyses or risk arguments. The staff believes that based on the information available, inspections as recommended in the bulletin are the only means to provide reasonable assurance of the structural integrity of the reactor vessel head. Therefore, any future discussions or submittals on this subject should focus on how Davis-Besse is unique or can be distinguished from the inspection results from the other, high susceptible facilities.

Sincerely, Stephen P. Sands, Project Manager, Section 2 Project Directorate Ill Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-346 cc: See next page Distribution PUBLIC LPD3-2 R/F SSands LBurkhart JZwolinski AMendiola AHiser JZimmerman WBateman KWichman JStrosnider JChung DPickett RBarrett MReinhart GGrant, R3 A -* I-* r",

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OFFICE PM:LPD3 LA:LPD3 BC:EMCB DD:DSSA SC:LPD3 NAME S. Sands T. Harris W. Bateman S. Black A. Mendiola DATE 11/ /01 11/ /01 11/ /01 11/ /01 11/ /01 rlflC.I IMINT NAME: G\PDIII-2\DAVISBES\Telecon of 11-15-01 .wpd OFFICIAL RECORD COPY

Mr. Guy G. Campbell Davis-Besse Nuclear Power Station, Unit 1 FirstEnergy Nuclear Operating Company cc:

Mary E. O'Reilly Dennis Clum FirstEnergy Radiological Assistance Section Supervisor 76 South Main Street Bureau of Radiation Protection Akron, OH 44308 Ohio Department of Health P.O. Box 118 Manager - Regulatory Affairs Columbus, OH 43266-0118 FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Carol O'Claire, Chief, Radiological Branch 5501 North State - Route 2 Ohio Emergency Management Agency Oak Harbor, OH 43449-9760 2855 West Dublin Granville Road Columbus, OH 43235-2206 Jay E. Silberg, Esq.

Shaw, Pittman, Potts Director and Trowbridge Ohio Department of Commerce 2300 N Street, NW. Division of Industrial Compliance Washington, DC 20037 Bureau of Operations & Maintenance 6606 Tussing Road Regional Administrator P.O. Box 4009 U.S. Nuclear Regulatory Commission Reynoldsburg, OH 43068-9009 801 Warrenville Road Lisle, IL 60523-4351 Ohio Environmental Protection Agency DERR--Compliance Unit Michael A. Schoppman ATTN: Zack A. Clayton Framatome ANP P.O. Box 1049 1700 Rockville Pike, Suite 525 Columbus, OH 43266-0149 Rockville, MD 20852 State of Ohio Resident Inspector Public Utilities Commission U.S. Nuclear Regulatory Commission 180 East Broad Street 5503 North State Route 2 Columbus, OH 43266-0573 Oak Harbor, OH 43449-9760 Attorney General Plant Manager Department of Attorney FirstEnergy Nuclear Operating Company 30 East Broad Street Davis-Besse Nuclear Power Station Columbus, OH 43216 5501 North State - Route 2 Oak Harbor, OH 43449-9760 President, Board of County Commissioners of Ottawa County Port Clinton, OH 43252