ML023260058

Regulatory Commitment Change Summary Report (May 18, 2000 - May 18, 2002)

ML023260058
Person / Time
Site:	Davis Besse
Issue date:	11/18/2002
From:	Meyers L FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML023260058 (13)

Text

FENOC "FEN  % 5501 North State Route 2 FirstEnergy Nuclear OperatingCompany Oak Harbor,Ohio 43449 Lew W. Myers 419-321-7599 Chief Operating Officer Fax 419-321-7582 Docket Number 50-346 License Number NPF-3 Serial 2824 November 18, 2002 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001

Subject:

Regulatory Commitment Change Summary Report (May 18, 2000 - May 18, 2002)

Ladies and Gentlemen:

The FirstEnergy Nuclear Operating Company (FENOC) hereby submits the attached Regulatory Commitment Change Summary Report for the Davis-Besse Nuclear Power Station, Unit Number 1 (DBNPS), pursuant to the Nuclear Energy Institute (NEI) document, "Guideline for Managing NRC Commitments," Revision 2, dated December 19, 1995. DBNPS adopted the above guideline with a revision to the Commitment Management procedure effective April 1, 1996.

The DBNPS commitment changes identified between the dates of May 18, 2000 and May 18, 2002 are included in Attachment 1 of this report. This report includes a description of the identified commitments, a summary of the changes made to the commitments, and a brief statement describing the basis for the change. The DBNPS has reviewed and implemented the commitment changes in accordance with the NEI document, "Guideline for Managing NRC Commitments." Per this guideline, DBNPS has determined that the submittal of this report is the only required notification regarding changes to commitments listed in the attached summary.

Also included in this report are six commitment changes recently identified that should have been included in the Regulatory Commitment Change Summary Report (Serial 2575) submitted on November 20, 1998. They are summarized in Attachment 2 to this report.

If you have any further questions concerning this matter, please contact Mr. Patrick McCloskey, Manager Regulatory Affairs at (419) 321-8450.

Sincerely yours, RJS/bw *-----------*

Attachments cc: J. B. Hopkins, DB-1 NRC/NRR Senior Project Manager J. E. Dyer, Regional Administrator, USNRC Region III C. S. Thomas, DB-1 NRC Senior Resident Inspector Utility Radiological Safety Board SAOc

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 1 of 9 Commitment Commitment Change Reason for Change Number / Source / Date Description 001256 Door 400 (Spent Fuel Pool EVS This commitment is closed. The This requirement is discussed as LER 82-057, Rev 1 negative pressure boundary) was "Basic Security Procedure" part of training received for 07/06/1984 found not completely closed and signature page stating station Protected Area Access. This latched due to personnel error. personnel are responsible for commitment is unnecessary Corrective Action was to have all ensuring plant doors close behind based on the quality of this sign a page in a "Basic Security them has been superceded by training and the maturity of the Procedures" document stating other program requirements and Access Authorization Program.

they are responsible for ensuring can be cancelled.

plant doors close behind them.

001275 Procedures are in place to ensure Procedures specify Revised procedural guidance to LER 83-012 Rev. 2 that if one ECCS Room Cooler (or isolating/draining a single ECCS incorporate licensing basis 05/05/83 one ECCS Cooler in each room) is Room Cooler for a given ECCS assumptions of License isolated, that the Service Water Room will render an associated Amendment 242, which increased temperature is less than or equal Train of ECCS components the maximum Service Water to 75 degrees Fahrenheit. (DH/LPI/HPI & CTMT Spray) temperature from 85 degrees inoperable unless Service Water Fahrenheit to 90 degrees temperature is below specified Fahrenheit.

values and other specified conditions are acceptable.

003558 Prohibit suspension of a work Commitment closed. The site procedures and the work Log 1-0401 order. order software do not provide or 01/06/1984 allow an option to suspend a work order.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 2 of 9 Commitment Commitment Change Reason for Change Number / Source / Date Description 004239 Maintain PM activities for Delete PM activities requiring the A modification removed the Serial 1-1033 applicable Agastat relays with replacement of the Agastat relays Agastat relays for electrical 01/28/1994 appropriate replacement for electrical schemes AC108, schemes AC108, AC113, AD108 frequency. AC113, ADi08 & AD113. & AD1 13 from the plant. Since the relays have been removed, the PMs are no longer applicable.

008625 Maintain a list of qualified design Commitment closed. A formal training program is now LER 88-008 reviewers. Maintenance of a separate list of in effect to ensure engineers 04/08/1988 qualified reviewers is not assigned design review administratively necessary. responsibility meet job specific qualifications. It is the responsibility of the Engineering Supervisor to ensure the assigned reviewer is qualified for the task assigned.

012223 Verify the CAC fans are Revise commitment to permit Permit alternate means of SERIAL 1-0645 discharging air in slow speed to alternate means of verifying verifying airflow if plenum 08/14/1986 show it is running in the proper airflow (e.g., plenum pressure, pressure transmitter fails during direction. Air flow is determined motor current, differential power operations. Subsequent by monitoring CAC plenum temperatures, or other methods). maintenance on the failed plenum pressure. pressure transmitter would require an "at power" containment entry in a high radiation area. This is unnecessary as alternate means exist to verify the CACs are operating properly.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 3 of 9 Commitment Commitment Change Reason for Change Number / Source / Date Description 013608 Changes to drawings contained in Commitment closed. Commitment was initiated due to IR 84-015 (Log 1-0490) the FSAR should be subject to oversight by personnel in early 01/14/1985 10CFR50.59 evaluation 1980's. Consideration that an evaluation is required for changes to USAR Drawings is now implicit in the fact that the drawings are part of the USAR.

013660/013661 Category A valve leak rate test Commitments have been The Third Ten Year ASME IST Serial 1-0526 program meets the requirements superseded by new requirements Program follows the 1995 Edition, 5/17/1985 of ASME Section X1, IWV-3426 and, therefore, are closed. 1996 Addenda of the OM Code for and IWV-3427. valve leak testing.

013663 Provide procedural requirement Commitment closed. Standardization and improved IR 87-004 (Log 1-1600) that a copy of all 10CFR50.59 efficiency of work process.

05/08/1987 safety evaluations be provided to A web page has been established Nuclear Licensing Manager for for electronic filing and retrieval of incorporation into annual report to 50.59 evaluations from which RA NRC. is able to retrieve copies of all required safety evaluations.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 4 of 9 Commitment Commitment Change Reason for Change Number / Source / Date Description 013771 PM program provides: Changes to the PM approval Changes in the review/approval Serial 1231 New, revised or deleted PM items levels are as follows: level is based upon past 01/03/1986 (PMAs) are approved by New, revised or deleted PM items performance of the PM program.

designated engineer, maintenance - designated engineer or Deferrals for the last 2 years have planner or supervisor work control; maintenance planner or PM been less than the maximum goal deferrals for PM items (PMDs) Coordinator (EQRL Engineer); and no deferrals past the grace which do not exceed 125% deferrals for PM items which do period (>125%) have been performance window are not exceed 125% performance submitted since 1999.

approved by supervisor work window - N/A; deferrals for PM control or discipline maintenance items which allow the item to superintendent; deferrals for PM exceed the 125% performance items which allow the item to window - plant operations exceed the 125% performance manager or discipline window are approved by plant maintenance superintendent.

operations manager or plant maintenance manager.

013930 Perform calibration of PZR code The pressure gauge used to Conformance with current Code IR 88-006 (Log 1-1783) safety valves and PORV under hot determine the lift setpoint will meet requirements. The old Code gave 04/20/1988 conditions. Pressure gauge used current OMa Code or ASME Xl no tolerance. The new Code to determine lift setpoint to have requirements used by DBNPS. gives a tolerance that is less an accuracy of plus or minus 0.1% stringent but adequate to ensure and a corresponding error of 5 psi. that testing requirements are met.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 5 of 9 Commitment Commitment Change Reason for Change Number / Source / Date Description 014906 The Emergency Planning Activity Procedure specifies activities that To permit evaluation and tracking Serial 1-0501 Scheduling System will be used to will be tracked in the Emergency of Emergency Preparedness 02/28/1985 identify and maintain Planning Activity Scheduling related "conditions adverse to commitments, required activities, System and specifies activities quality" in the DBNPS Condition routing activities and correction of involving corrective actions to be Report system similar to other action items. tracked in the DBNPS corrective identified conditions adverse to action program. quality.

015078 Main Steam Line Room smoke Commitment closed. A modification abandoned these Serial 1685 detectors are verified for Main Steam line Room smoke 07/31/1989 operability every 18 months and detectors.

when the unit has been shutdown for maintenance.

015085 The Emergency Planning Activity Procedure specifies activities that To permit evaluation and tracking Serial 1-0501 Scheduling System will be used to will be tracked in the Emergency of Emergency Preparedness 02/28/1985 track all Emergency Preparedness Planning Activity Scheduling related "conditions adverse to activities including NRC and INPO System and specifies activities quality" in the DBNPS Condition commitments, drill and exercise involving corrective actions to be Report system similar to other critique items, required tracked in the DBNPS corrective identified conditions adverse to performance tests, required action program. quality.

training, and Quality Assurance audit finding reports.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 6 of 9 Commitment Commitment Change Reason for Change Number / Source / Date Description 015277 Sample the Diesel Fire Pump Eliminated monthly sampling of Actions changed to be in Serial 1685 lubricating oil monthly to meet the the lubricating oil of the Diesel Fire compliance with standard NFPA 7/31/1989 intent of standard NFPA 13A Pump. Oil is now replaced every 13A 1982, 2-4.1.6.

1981, 2-4.1.6. The oil is changed 12 months.

at 18-month intervals instead of annually as specified in the standard.

015554/015555 Control Room Emergency CREVS Condenser Units are The change to the frequency is a GL 89-013 (Log 2997) Ventilation System Condenser inspected and cleaned (if precautionary measure to ensure 07/18/89 Units are cleaned at least once required) at least once every 18 early detection/elimination of a every 36 months. months. potential bio-fouling condition.

Although bio-fouling has not been historically found in the CREVS system, the frequency should be increased as a precautionary measure to ensure early detection/elimination.

015555 Test the Decay Heat Cooler Remove testing of the Decay Heat The CCW system does not obtain GL 89-013 (Log 2997) performance every 5 years. Coolers from the GL 89-013 make up from the SW system and 07/18/1989 Program. chemistry controls are routinely well maintained. Heat transfer testing and visual inspections of CCW heat exchangers in the last 10 years have not identified any conditions of degraded heat transfer.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 7 of 9 Commitment Commitment Change Reason for Change Number / Source / Date Description 015555 Conduct CCW Heat Exchanger CCW Heat Exchanger testing now Follow up inspections have not GL 89-013 (Log 2997) performance testing once per year done one each year: each heat identified any fouling in recent 07/18/1989 for the GL 89-013 program. exchanger is tested once every 3 years. The reason for not meeting years. previous tests was found to be poor test design which has been improved.

015921 Monitor MU Pump performance to The alert level at which action was A calculation provided the Serial 1836 ensure that feed and bleed required has been deleted. The appropriate value to be used in 09/18/1990 capability is maintained by surveillance procedure contains a the surveillance test.

requiring action at an alert level set value at which action is when the MU Pump appears to be required.

degrading.

016667 Procedures include preoperational The commitment now only applies The Third Ten-year Interval IST LER 92-003 checks of surveillance to two valves SW 1424 and Program has on-line testing 4/22/1992 requirements for their associated SW 1429. requirements for SW 1424 and IST valves. SW 1429. The other valves previously in the commitment are tested only when the plant is shutdown per the Third Ten-Year Interval IST Program.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 8 of 9 Commitment Commitment Change Reason for Change Number / Source / Date Description 017419 Valves SW232, SW233, SW236 Commitment closed. The function of these valves has IR 93-016 (Log 1-2963) and SW234 (SW to CCW cross been reviewed and reclassified 12/29/1993 connect valves) are exercised and now are considered to fall once each cycle to ensure valve under the ASME Code reliability. requirements. The ASME Code requires these valves be part of the IST Program and, therefore, are included in the current Second Interval IST Program.

017955 Annual PM activities perform PM frequency changed from After five years of monitoring with IR 94-017-02 (Log 1-3550) electronic characteristic and annual to every two years. no evidence of water intrusion the 02/13/1995 diagnostic (ECAD) testing on PM periodicity has been re cables known to be in a wet assessed. The original interval environment. was a conservative frequency.

018252 Breakers required to connect the Breakers will be verified to be in The fuse blocks were changed out Amendment 206 (Log 4795) SBODG to the essential bus the position required for the to due to the wear and 02/26/1996 associated with the EDG removed existing operational mode and unavailability of the old fuse from service will be verified to be plant conditions, with close and blocks. The new fuse blocks do in the position required for the trip fuses installed by a visual not allow direct sight of the existing operational mode and verification that the fuse block is installed fuse.

plant conditions, with close and closed without any clearance tags.

trip fuses installed through a breaker line-up check.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 9 of 9 Commitment Commitment Change Reason for Change Number / Source / Date Description 018574 Maintain Control Room Pressure Maximum permissible opening for Revised Calculation determined LER 96-007 Boundary openings less than 3 the Control Room positive the maximum permissible opening 11/14/1996 square inches to ensure no Pressure Boundary is 7.5 square for the Control Room Pressure unattended openings exist inches. Boundary to be 7.5 square inches between the CREVS fan and the with the Control Room Equipment filter housing. Fan running.

018789 The Start-up Transformers 01 & Commitment closed. A modification installed a LER 97-010 02 Deluge Tests periodically "permissive interlock" which 06/03/1997 check the temperature sensors to requires the start-up transformer ensure the setpoint of the sensors to be de-energized before the has not drifted outside acceptable deluge system will initiate.

values. This eliminates spurious Additionally, the detector actuation transformer fire protection deluge is an "alarm only" function and a system actuations. low setpoint will no longer result in an automatic actuation of the deluge system, eliminating the potential for a spurious deluge actuation.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 1 of 2 Commitment Commitment Change Reason for Change Number / Source / Date Description 004851 Administrative controls preclude Lanyards are no longer required to The use of lanyards was an over GL 85-002, Serial 1161 the introduction of foreign objects for tools used within the Steam commitment in response to the 4/17/1985 into the Steam Generators during Generators. Generic Letter requirements, and maintenance. Accountability of is not practical in all cases. Tool tools and equipment is maintained accountability is still maintained by entry and exit logs. All tools through the use of entry and exit used are attached to lanyards. logs.

005641 Polyethylene filtered bottles are The use of polyethylene filter It is not the best practice for GL 87-012, Serial 1423 used to vent the RCS to bottles is optional when venting maintaining dose As Low As 7/9/1987 containment to trap moisture and the RCS. Reasonable Achievable (ALARA) contaminants. to require polyethylene filter bottles at all vent points at all times.

013548/013563 Maintain maintenance procedure Deleted requirement to inspect Bulletin 82-002 did not require the Bulletin 82-002, IR 84-028-07 to inspect threaded fasteners threaded fasteners via magnetic use of non-destructive 1/18/1985 during disassembly, inspection, particle non-destructive examination methods (such as repair and re-assembly of the examination methods. Procedure magnetic particle examination) to Reactor Coolant Pump. still performs visual inspection of inspect threaded fasteners.

Fasteners are inspected visually fasteners.

and by utilizing magnetic particle non-destructive examination methods.

Docket Number 50-346 DAVIS-BESSE NUCLEAR POWER STATION License Number NPF-3 COMMITMENT CHANGE SUMMAY REPORT Serial Number 2824 MAY, 2000 - MAY, 2002 Page 2 of 2 Commitment Commitment Change Reason for Change Number / Source / Date Description 013804 Maintain maintenance procedure Commitment closed. The Turbine Bypass Valves for LER 88-028 to ensure proper setup of the which this commitment applied 1/16/1989 positioner and travel stop for the were replaced with a completely Turbine Bypass Valves. different style valve and actuator.

014530 Maintain calibration procedure to Commitment closed. The Turbine Bypass Valves for IR 87-025, Log 1-1678 clearly establish the testing which this commitment applied 10/1/1987 connections, provide for tighter were replaced with a completely alignment criteria, and verify different style valve and actuator.

mechanical and electrical limits of the Turbine Bypass Valves.

Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 1 of 1 List of Abbreviations Used ASME American Society of Mechanical Engineers CAC Containment Air Cooler CCW Component Cooling Water CREVS Control Room Emergency Ventilation System DBNPS Davis-Besse Nuclear Power Station EDG Emergency Diesel Generator EVS Emergency Ventilation System GL Nuclear Regulatory Commission Generic Letter IR Nuclear Regulatory Commission Inspection Report IST Inservice Testing LER Licensee Event Report MU Make-Up NRC Nuclear Regulatory Commission PM Preventive Maintenance PORV Pressurizer Operated Relief Valves PZR Pressurizer RCS Reactor Coolant System SBODG Station Blackout Diesel Generator SERIAL Letter from Davis-Besse Nuclear Power Station to Nuclear Regulatory Commission SW Service Water USAR Updated Safety Analysis Report