ML023260058
| 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 Operating Company 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 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 License Number NPF-3 Serial Number 2824 Page 1 of 9 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 001256 LER 82-057, Rev 1 07/06/1984 001275 LER 83-012 Rev. 2 05/05/83 Door 400 (Spent Fuel Pool EVS negative pressure boundary) was found not completely closed and latched due to personnel error.
Corrective Action was to have all sign a page in a "Basic Security Procedures" document stating they are responsible for ensuring plant doors close behind them.
Procedures are in place to ensure that if one ECCS Room Cooler (or one ECCS Cooler in each room) is isolated, that the Service Water temperature is less than or equal to 75 degrees Fahrenheit.
This commitment is closed. The "Basic Security Procedure" signature page stating station personnel are responsible for ensuring plant doors close behind them has been superceded by other program requirements and can be cancelled.
Procedures specify isolating/draining a single ECCS Room Cooler for a given ECCS Room will render an associated Train of ECCS components (DH/LPI/HPI & CTMT Spray) inoperable unless Service Water temperature is below specified values and other specified conditions are acceptable.
This requirement is discussed as part of training received for Protected Area Access. This commitment is unnecessary based on the quality of this training and the maturity of the Access Authorization Program.
Revised procedural guidance to incorporate licensing basis assumptions of License Amendment 242, which increased the maximum Service Water temperature from 85 degrees Fahrenheit to 90 degrees Fahrenheit.
Prohibit suspension of a work order.
Commitment closed.
The site procedures and the work order software do not provide or allow an option to suspend a work order.
Reason for Change 003558 Log 1-0401 01/06/1984
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 2 of 9 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 004239 Serial 1-1033 01/28/1994 008625 LER 88-008 04/08/1988 012223 SERIAL 1-0645 08/14/1986 Maintain PM activities for applicable Agastat relays with appropriate replacement frequency.
Maintain a list of qualified design reviewers.
Verify the CAC fans are discharging air in slow speed to show it is running in the proper direction. Air flow is determined by monitoring CAC plenum pressure.
Delete PM activities requiring the replacement of the Agastat relays for electrical schemes AC108, AC113, ADi08 & AD113.
Commitment closed.
Maintenance of a separate list of qualified reviewers is not administratively necessary.
Revise commitment to permit alternate means of verifying airflow (e.g., plenum pressure, motor current, differential temperatures, or other methods).
A modification removed the Agastat relays for electrical schemes AC108, AC113, AD108
& AD1 13 from the plant. Since the relays have been removed, the PMs are no longer applicable.
A formal training program is now in effect to ensure engineers assigned design review responsibility meet job specific qualifications. It is the responsibility of the Engineering Supervisor to ensure the assigned reviewer is qualified for the task assigned.
Permit alternate means of verifying airflow if plenum pressure transmitter fails during power operations. Subsequent maintenance on the failed plenum 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.
Reason for Change
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 3 of 9 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 013608 IR 84-015 (Log 1-0490) 01/14/1985 013660/013661 Serial 1-0526 5/17/1985 013663 IR 87-004 (Log 1-1600) 05/08/1987 Changes to drawings contained in the FSAR should be subject to 10CFR50.59 evaluation Category A valve leak rate test program meets the requirements of ASME Section X1, IWV-3426 and IWV-3427.
Provide procedural requirement that a copy of all 1 OCFR50.59 safety evaluations be provided to Nuclear Licensing Manager for incorporation into annual report to NRC.
Commitment closed.
Commitments have been superseded by new requirements and, therefore, are closed.
Commitment closed.
Commitment was initiated due to oversight by personnel in early 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.
The Third Ten Year ASME IST Program follows the 1995 Edition, 1996 Addenda of the OM Code for valve leak testing.
Standardization and improved efficiency of work process.
A web page has been established for electronic filing and retrieval of 50.59 evaluations from which RA is able to retrieve copies of all required safety evaluations.
Reason for Change
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 4 of 9 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 013771 Serial 1231 01/03/1986 013930 IR 88-006 (Log 1-1783) 04/20/1988 PM program provides:
New, revised or deleted PM items (PMAs) are approved by designated engineer, maintenance planner or supervisor work control; deferrals for PM items (PMDs) which do not exceed 125%
performance window are approved by supervisor work control or discipline maintenance superintendent; deferrals for PM items which allow the item to exceed the 125% performance window are approved by plant operations manager or plant maintenance manager.
Perform calibration of PZR code safety valves and PORV under hot conditions. Pressure gauge used to determine lift setpoint to have an accuracy of plus or minus 0.1%
and a corresponding error of 5 psi.
Changes to the PM approval levels are as follows:
New, revised or deleted PM items
- designated engineer or maintenance planner or PM Coordinator (EQRL Engineer);
deferrals for PM items which do not exceed 125% performance window - N/A; deferrals for PM items which allow the item to exceed the 125% performance window - plant operations manager or discipline maintenance superintendent.
The pressure gauge used to determine the lift setpoint will meet current OMa Code or ASME Xl requirements used by DBNPS.
Changes in the review/approval level is based upon past performance of the PM program.
Deferrals for the last 2 years have been less than the maximum goal and no deferrals past the grace period (>125%) have been submitted since 1999.
Conformance with current Code requirements. The old Code gave no tolerance. The new Code gives a tolerance that is less stringent but adequate to ensure that testing requirements are met.
Reason for Change
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 5 of 9 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 014906 Serial 1-0501 02/28/1985 015078 Serial 1685 07/31/1989 015085 Serial 1-0501 02/28/1985 The Emergency Planning Activity Scheduling System will be used to identify and maintain commitments, required activities, routing activities and correction of action items.
Main Steam Line Room smoke detectors are verified for operability every 18 months and when the unit has been shutdown for maintenance.
The Emergency Planning Activity Scheduling System will be used to track all Emergency Preparedness activities including NRC and INPO commitments, drill and exercise critique items, required performance tests, required training, and Quality Assurance audit finding reports.
Procedure specifies activities that will be tracked in the Emergency Planning Activity Scheduling System and specifies activities involving corrective actions to be tracked in the DBNPS corrective action program.
Commitment closed.
Procedure specifies activities that will be tracked in the Emergency Planning Activity Scheduling System and specifies activities involving corrective actions to be tracked in the DBNPS corrective action program.
To permit evaluation and tracking of Emergency Preparedness related "conditions adverse to quality" in the DBNPS Condition Report system similar to other identified conditions adverse to quality.
A modification abandoned these Main Steam line Room smoke detectors.
To permit evaluation and tracking of Emergency Preparedness related "conditions adverse to quality" in the DBNPS Condition Report system similar to other identified conditions adverse to quality.
Reason for Change
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 6 of 9 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 015277 Serial 1685 7/31/1989 015554/015555 GL 89-013 (Log 2997) 07/18/89 015555 GL 89-013 (Log 2997) 07/18/1989 Sample the Diesel Fire Pump lubricating oil monthly to meet the intent of standard NFPA 13A 1981, 2-4.1.6. The oil is changed at 18-month intervals instead of annually as specified in the standard.
Control Room Emergency Ventilation System Condenser Units are cleaned at least once every 36 months.
Test the Decay Heat Cooler performance every 5 years.
Eliminated monthly sampling of the lubricating oil of the Diesel Fire Pump. Oil is now replaced every 12 months.
CREVS Condenser Units are inspected and cleaned (if required) at least once every 18 months.
Remove testing of the Decay Heat Coolers from the GL 89-013 Program.
Actions changed to be in compliance with standard NFPA 13A 1982, 2-4.1.6.
The change to the frequency is a precautionary measure to ensure early detection/elimination of a 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.
The CCW system does not obtain make up from the SW system and 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.
Reason for Change
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 7 of 9 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 015555 GL 89-013 (Log 2997) 07/18/1989 015921 Serial 1836 09/18/1990 016667 LER 92-003 4/22/1992 Conduct CCW Heat Exchanger performance testing once per year for the GL 89-013 program.
Monitor MU Pump performance to ensure that feed and bleed capability is maintained by requiring action at an alert level when the MU Pump appears to be degrading.
Procedures include preoperational checks of surveillance requirements for their associated IST valves.
CCW Heat Exchanger testing now done one each year: each heat exchanger is tested once every 3 years.
The alert level at which action was required has been deleted. The surveillance procedure contains a set value at which action is required.
The commitment now only applies to two valves SW 1424 and SW 1429.
Follow up inspections have not identified any fouling in recent years. The reason for not meeting previous tests was found to be poor test design which has been improved.
A calculation provided the appropriate value to be used in the surveillance test.
The Third Ten-year Interval IST Program has on-line testing requirements for SW 1424 and 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.
Reason for Change
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 8 of 9 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 017419 IR 93-016 (Log 1-2963) 12/29/1993 017955 IR 94-017-02 (Log 1-3550) 02/13/1995 018252 Amendment 206 (Log 4795) 02/26/1996 Valves SW232, SW233, SW236 and SW234 (SW to CCW cross connect valves) are exercised once each cycle to ensure valve reliability.
Annual PM activities perform electronic characteristic and diagnostic (ECAD) testing on cables known to be in a wet environment.
Breakers required to connect the SBODG to the essential bus associated with the EDG removed from service will be verified to be in the position required for the existing operational mode and plant conditions, with close and trip fuses installed through a breaker line-up check.
Commitment closed.
PM frequency changed from annual to every two years.
Breakers will be verified to be in the position required for the existing operational mode and plant conditions, with close and trip fuses installed by a visual verification that the fuse block is closed without any clearance tags.
The function of these valves has been reviewed and reclassified and now are considered to fall under the ASME Code requirements. The ASME Code requires these valves be part of the IST Program and, therefore, are included in the current Second Interval IST Program.
After five years of monitoring with no evidence of water intrusion the PM periodicity has been re assessed. The original interval was a conservative frequency.
The fuse blocks were changed out to due to the wear and unavailability of the old fuse blocks. The new fuse blocks do not allow direct sight of the installed fuse.
Reason for Change
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 9 of 9 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change Maintain Control Room Pressure Boundary openings less than 3 square inches to ensure no unattended openings exist between the CREVS fan and the filter housing.
The Start-up Transformers 01 &
02 Deluge Tests periodically check the temperature sensors to ensure the setpoint of the sensors has not drifted outside acceptable values. This eliminates spurious transformer fire protection deluge system actuations.
Maximum permissible opening for the Control Room positive Pressure Boundary is 7.5 square inches.
Commitment closed.
Revised Calculation determined the maximum permissible opening for the Control Room Pressure Boundary to be 7.5 square inches with the Control Room Equipment Fan running.
A modification installed a "permissive interlock" which requires the start-up transformer to be de-energized before the deluge system will initiate.
Additionally, the detector actuation is an "alarm only" function and a low setpoint will no longer result in an automatic actuation of the deluge system, eliminating the potential for a spurious deluge actuation.
018574 LER 96-007 11/14/1996 018789 LER 97-010 06/03/1997 Reason for Change
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 1 of 2 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 004851 GL 85-002, Serial 1161 4/17/1985 005641 GL 87-012, Serial 1423 7/9/1987 013548/013563 Bulletin 82-002, IR 84-028-07 1/18/1985 Administrative controls preclude the introduction of foreign objects into the Steam Generators during maintenance. Accountability of tools and equipment is maintained by entry and exit logs. All tools used are attached to lanyards.
Polyethylene filtered bottles are used to vent the RCS to containment to trap moisture and contaminants.
Maintain maintenance procedure to inspect threaded fasteners during disassembly, inspection, repair and re-assembly of the Reactor Coolant Pump.
Fasteners are inspected visually and by utilizing magnetic particle non-destructive examination methods.
Lanyards are no longer required to for tools used within the Steam Generators.
The use of polyethylene filter bottles is optional when venting the RCS.
Deleted requirement to inspect threaded fasteners via magnetic particle non-destructive examination methods. Procedure still performs visual inspection of fasteners.
The use of lanyards was an over commitment in response to the Generic Letter requirements, and is not practical in all cases. Tool accountability is still maintained through the use of entry and exit logs.
It is not the best practice for maintaining dose As Low As Reasonable Achievable (ALARA) to require polyethylene filter bottles at all vent points at all times.
Bulletin 82-002 did not require the use of non-destructive examination methods (such as magnetic particle examination) to inspect threaded fasteners.
Reason for Change
Docket Number 50-346 License Number NPF-3 Serial Number 2824 Page 2 of 2 Commitment Number / Source / Date DAVIS-BESSE NUCLEAR POWER STATION COMMITMENT CHANGE SUMMAY REPORT MAY, 2000 - MAY, 2002 Commitment Description Change 013804 LER 88-028 1/16/1989 014530 IR 87-025, Log 1-1678 10/1/1987 Maintain maintenance procedure to ensure proper setup of the positioner and travel stop for the Turbine Bypass Valves.
Maintain calibration procedure to clearly establish the testing connections, provide for tighter alignment criteria, and verify mechanical and electrical limits of the Turbine Bypass Valves.
Commitment closed.
Commitment closed.
The Turbine Bypass Valves for which this commitment applied were replaced with a completely different style valve and actuator.
The Turbine Bypass Valves for which this commitment applied were replaced with a completely different style valve and actuator.
Reason for Change
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