ML032890545

Request for Additional Information Re License Amendment Request

ML032890545
Person / Time
Site:	Davis Besse
Issue date:	10/28/2003
From:	Lyon C NRC/NRR/DLPM/LPD3
To:	Myers L FirstEnergy Nuclear Operating Co
Lyon C, NRR/DLPM, 415-2296
References
TAC MC0366
Download: ML032890545 (5)

Text

October 28, 2003 Mr. Lew W. Myers Chief Operating Officer FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST (TAC NO. MC0366)

Dear Mr. Myers:

By application dated August 11, 2003, FirstEnergy Nuclear Operating Company requested a license amendment to relocate Surveillance Requirement (SR) 4.5.2.f from the technical specifications to the Technical Requirements Manual. SR 4.5.2.f requires periodic performance of a vacuum leakage rate test of the watertight enclosure for valves DH-11 and DH-12. Based on the staffs review of your application, please provide additional information as discussed in the enclosure to this letter.

The enclosed request was discussed with Mr. D. Wuokko of your staff on October 8, 2003. A mutually agreeable target date of January 4, 2004, for your response was established. If circumstances result in the need to revise the target date, please contact me at (301) 415-2296 at the earliest opportunity.

Sincerely,

/RA/

Carl F. Lyon, Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

Request for Additional Information cc w/encl: See next page

ML032890545 *Memo dated 9/29/03 OFFICE PDIII-2/PM PDIII-2/LA SPLB/SC PDIII-2/SC NAME FLyon THarris DSolorio* AMendiola DATE 10/23/03 10/22/03 9/29/03 10/28/03 Davis-Besse Nuclear Power Station, Unit 1 cc:

Mary E. OReilly FirstEnergy Corporation 76 South Main St.

Akron, OH 44308 Carol OClaire, Chief, Radiological Branch Ohio Emergency Management Agency Manager - Regulatory Affairs 2855 West Dublin Granville Road First Energy Nuclear Operating Company Columbus, OH 43235-2206 Davis-Besse Nuclear Power Station Oak Harbor, OH 43449-9760 Zack A. Clayton DERR Director Ohio Environmental Protection Agency Ohio Department of Commerce P.O. Box 1049 Division of Industrial Compliance Columbus, OH 43266-0149 Bureau of Operations & Maintenance 6606 Tussing Road State of Ohio P.O.Box 4009 Public Utilities Commission Reynoldsburg, OH 43068-9009 180 East Broad Street Columbus, OH 43266-0573 Regional Administrator U.S. Nuclear Regulatory Commission Attorney General 801 Warrenville Road Department of Attorney Lisle, IL 60523-4351 30 East Broad Street Columbus, OH 43216 Michael A. Schoppman Framatome ANP President, Board of County 1911 N. Ft. Myer Drive Commissioners of Ottawa County Rosslyn, VA 22209 Port Clinton, OH 43252 Resident Inspector President, Board of County U.S. Nuclear Regulatory Commission Commissioners of Lucas County 5503 North State Route 2 One Government Center, Suite 800 Oak Harbor, OH 43449-9760 Toledo, Ohio 43604-6506 Plant Manager, Randel J. Fast David Lochbaum, Nuclear Safety Engineer FirstEnergy Nuclear Operating Company Union of Concerned Scientists Davis-Besse Nuclear Power Station 1707 H Street NW, Suite 600 5501 North State - Route 2 Washington, DC 20006 Oak Harbor, OH 43449-9760 The Honorable Dennis J. Kucinich Dennis Clum United States House of Representatives Radiological Assistance Section Supervisor Washington, D.C. 20515 Bureau of Radiation Protection Ohio Department of Health The Honorable Dennis J. Kucinich, Member P.O. Box 118 United States House of Representatives Columbus, OH 43266-0118 14400 Detroit Avenue Lakewood, OH 44107

REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST DATED AUGUST 11, 2003 FIRSTENERGY NUCLEAR OPERATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 DOCKET NO. 50-346

1. The proposed technical specification (TS) change would relocate Surveillance Requirement (SR) 4.5.2.f to the updated safety analysis report (USAR) Technical Requirements Manual (TRM). However, the submittal does not address the requirement of 10 CFR 50.36(c)(3) to provide a reason why it is acceptable to remove this SR from the TSs. SRs are in place to verify and/or demonstrate that the associated limiting conditions for operation (LCO) are being met. Please provide the basis for why the SR is not required to demonstrate that the associated LCO is being met.

2. TS LCO 3.5.2 requires two independent emergency core cooling system (ECCS) subsystems to be operable. SR 4.5.2.f requires each ECCS subsystem to be demonstrated operable by performing a vacuum leakage rate test on the watertight enclosure for decay heat removal system valves DH-11 and DH-12, to assure that the motor operators on the valves will not be flooded for at least 7 days following a loss-of-coolant accident (LOCA). The relocation of SR 4.5.2.f to USAR TRM will relax the immediate action required by the TS. Please explain any compensatory measures that will be implemented if this SR is moved to the USAR TRM.

3. If SR 4.5.2.f is relocated to the USAR TRM, explain (1) what changes (if any) will be made to the vacuum leakage rate test requirements on the watertight enclosure, (2) what criteria are used to determine test acceptability, and (3) what assurance is provided that the electric motor operators on the valves will not be flooded following a LOCA.

4. As stated in the submittal, the Bases associated with TS 3/4.5.2 will also be relocated to the USAR TRM. However, the provisions of the TS Bases Control program will no longer apply to the relocated Bases. Please describe the administrative controls program for the USAR TRM.

5. SR 4.5.2.f requires the watertight enclosure to be tested once per 18 months. The plant is currently operating on a 24-month fuel cycle. As stated in the submittal, the 18-month test frequency was added due to the design of the watertight enclosure, and was based upon performing testing at a refueling outage frequency rather than a fixed absolute time-span.

To avoid the need for performing the surveillance during mid-cycle outages, have you considered whether a change to the valve test interval to a 24-month frequency can be justified with a TS amendment, rather than making future changes to the relocated specification under 10 CFR 50.59?

6. The plant has two active means of boron precipitation control (BPC) that ensure the chemical additive concentration remains below its solubility limit throughout the post-accident cooling period. As stated in the submittal, the backup BPC method utilizes one of the two operating DH/LPI pumps taking suction from the DH drop line via valves DH-11 and DH-12, and discharges a throttled flow rate into the reactor vessel via the core flood nozzles. The submittal states that a plant modification is planned during the ongoing

thirteenth refueling outage to add a new cross-tie line and associated valving that allow the discharge of either DH/LPI pump to backflow through the DH-11 and DH-12 drop line and into the reactor vessel. The new primary BPC method would still utilize a flow path through valves DH-11 and DH-12. Therefore, the watertight enclosure is always important to ensure that the valves will remain capable of opening following a LOCA. SR 4.5.2.f provides assurance that at least one BPC method will be available post-LOCA. Please explain the safety basis for the two valves, including their purposes for boron control and for decay heat removal.