ML040550478
| ML040550478 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/23/2004 |
| From: | Myers L FirstEnergy Nuclear Operating Co |
| To: | Caldwell J Region 3 Administrator |
| References | |
| 1-1345, CAL 3-02-001 | |
| Download: ML040550478 (13) | |
Text
FENOC -
FirstEnergy Nuclear Operating Company 550 1 North State Route 2 Oak Harbor, Ohio 43449 Lew W. Myers Chbf 0,oerating Officer 4 19-32 1 - 7599 Fax: 4 19-32 1 - 7582 Docket Number 50-346 License Number NPF-3 Serial Number 1-1345 February 2 3, 2004 Mr. James L. Caldwell, Administrator United States Nuclear Regulatory Commission, Region III 801 Warrenville Road Lisle, IL 60532-43551
Subject:
Closure of Confirmatory Action Letter Items 4 and 5 and Completion of Confii-matory Action Letter 3-02-001
Dear Mr. Caldwell:
The purpose of this letter is to provide an update and request closure of the remaining open Confirmatory Action Letter (CAL) 3-02-001 Items four (4) and five (3, provide a status for the remaining CAL Items, and request closure of the CAL in its entirety.
As a result of the identification of degradation of the Davis-Besse Nuclear Power Station (DBNPS) Reactor Pressure Vessel (RPV) head in March 2002, the Nuclear Regulatory Commission (NRC) issued FirstEnergy Nuclear Operation Company (FENOC) CAL 3-02-00 1 on March 13, 2002, to document six specific activities FENOC intended to implement to resolve the RPV head degradation issue. As explained below, and in Attachment 1, FENOC has completed the actions specified for these open Items and each of the other CAL Items.
Therefore, FENOC respectfully requests the NRC close this CAL.
Confirmatory Action Letter, Item 4 CAL Item 4 states as follows:
Obtain NRC review and approval of the repair or modification and testing plans for the RPV head, prior to implementation of those activities. Prior to restart of the reactor, obtain NRC review and approval of any modification and testing activity related to the reactor core or reactivity control systems.
CAL Item 4 Status:
On December 24,2002, the NRC provided an CAL 3-02-001B Update of the original CAL 3-02-001. Confirmatory Action Letter Item 4 was statused to remain open pending successful
S L
Docket Number 50-346 License Number NPF-3 Serial Number 1-1345 Page 2 of 3 completion of the Reactor Coolant System pressure test and Control Rod Drive performance test.
Davis-Besse Nuclear Power Station (DBNPS) Serial Letter Number 1-1336, dated November 26, 2003, described the results of the Reactor Coolant System pressure test. FENOC reported, based on the test results, no outstanding items were identified. Also, FENOC committed to perform the Control Rod drop surveillance when the plant returned to Mode 3.
This Control Rod Drive performance testing, as committed to in Serial Letter 1-1336, Appendix C, Item 15, was a Control Rod drop surveillance test as performed by DBNPS procedure DB-SC-03270, Control Rod Assembly Insertion Time Test.
The Control Rod Drive performance testing was completed satisfactorily in accordance with procedure DB-SC-03270 on February 10,2004. The results of the individual Safety and Regulating Rod insertion times were equal to or less than 1.58 seconds as required by DBNPS Technical Specification 3.1.3.4.
This completes the actions required for CAL Item 4 and therefore, FENOC respectfully requests closure of this CAL Item.
Confirmatory Action Letter, Item 5 CAL Item 5 states as follows:
Prior to the restart of the unit, meet with the NRC to obtain restart approval. During that meeting, we expect you will discuss your root cause determination, extent of condition evaluations, and corrective actions completed and planned to repair the damage and prevent recurrence.
CAL Item 5 Status:
In the December 24,2002, NRC CAL 3-02-001B Update, Item 5 was statused to remain open pending submittal of the Integrated Restart Report summarizing the root cause determination, extent of condition evaluations, and corrective actions completed and planned to prevent recurrence. FENOC submitted the DBNPS Integrated Restart Report and Supplement, dated November 23,2003 (Serial Letter 1-1336), and February 6,2004 (Serial Letter 3026),
respectively. These letters provided an overall discussion of the DBNPS restart activities including: the causes of the RPV Head degradation; extent of condition reviews; systems, programs and organizational reviews. Corrective and preventive actions were taken as identified in the Integrated Restart Report and its Supplement. The restart activities, as reported in Serial Letter 3026 Attachment 3, have been completed or are being tracked to completion by the DBNPS Regulatory Commitment Tracking System (RCTS).
Additionally, the CAL 3-02-001B Update requested FENOC meet with the NRC to discuss the root causes, extent of condition, completed and planned corrective and preventive actions and provide justification for restart of the DBNPS. FENOC provided this information and described its plans for restart and long-term improvement for the DBNPS in a public meeting
Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1345 Page 3 of 3 with the NRC on February 12, 2004, at Camp Perry, Ohio. At this meeting FENOC requested approval for restart of the DBNPS.
Therefore, FENOC respectfully requests that CAL Item 5 be closed.
Confirmatory Action Letter 3-02-001-Completion The March 13,2002 CAL required FENOC to notify the NRC Regional Administrator, when the actions addressed in CAL 3-02-001 are complete. As previously described in this letter, and Attachment I, FENOC has completed the actions specified in each of the CAL Items. also lists the relevant FENOC correspondence for each CAL Item for reference.
Therefore, FENOC respectfully requests closure of CAL 3-02-001.
There are no new regulatory commitments contained in this letter. If there are any questions concerning this matter, please contact Mr. Gregory A. Dunn, Manager - Regulatory Affairs at 4 19-32 1-8450.
Sincerely,
JCSIs Attachments cc: U.S. NRC Document Control Desk John A. Grobe, Chairman NRC 0350 Panel DB-1 Senior NRC/NRR Project Manager DB-1 Senior NRC Resident Inspector Utility Radiological Safety Board
Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1345, Page 1 of 9 FENOCs Status of Completion of the Restart Confirmatory Action Letter 3-02-001 Confirmatow Action Letter, Item 1 CAL Item Description Quarantine components or other material from the RPV head and CRDM nozzle penetrations that are deemed necessary to fully address the root cause of the occurrence of degradation of the leaking penetrations. Prior to implementation, plans for further inspection and data gathering to support determination of the root cause will be provided to the NRC for review and comment.
NRCs Status CAL Update 3-02-001 E, dated September 19,2003 (Log 1-4445):
This issue is closed.
CAL Update 3-02-001E stated, the additional specimens described in the previous update to this Confirmatory Action Letter were obtained by the licensee and shipped to Battelle Northwest Laboratory (BNL) shortly after issuance of the last CAL update. The materials received at BNL were inventoried and NRC staff confirmed that the specimens identified in the CAL update had been received. Upon shipment of the specimens, the quarantine of the old reactor head was released, and the head was shipped for disposal on August 26,2003.
FENOCs Action As described in the original RPV Head degradation root cause report, FENOC created a plan to preserve and collect evidence necessary for the root cause investigation. As described above in the CAL 3-02-001E Update the degraded reactor vessel head was quarantined, cut samples of the areas of degradation for further data, and shipped those samples to the laboratory for analysis. The quarantine was then lifted and the RPV head was shipped off-site for disposal on August 26, 2003.
FENOC Submittal References Serial Letter 1-1270, dated April 18,2002; Root Cause Analysis Report Regarding Reactor Serial Letter 1-1275, dated May 21, 2002; DBNPS Return to Service Plan (Revision 0)
Serial Letter 2955, dated July 23,2003; Reactor Vessel Closure Head Welding Data Sheets Serial Letter 2968, dated August 13,2003; Final Report on Examination of Reactor Vessel Pressure Vessel Head Degradation Head Degradation and Safety Significance Assessment Update
Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1345, Page 2 of 9 FENOCs Status of Completion of the Restart Confirmatory Action Letter 3-02-001 Serial Letter 3004, dated November 8,2003; Disposition of Reactor Vessel Head Sample Serial Letter 3007, dated November 20,2003; Resubmittal of Final Report on Examination of Serial Letter 3019, dated February 13,2004; Disposition of Reactor Vessel Head Sample Piece A2B Reactor Vessel Head Degradation Pieces A2A7L, A2A7M, and A2A7N
Docket Number 50-346 License Number NPF-3 Serial Number 1-1345, Page 3 of 9 FENOCs Status of Completion of the Restart Confirmatory Action Letter 3-02-001 Confirmatory Action Letter, Item 2 CAL Item Description Determine the root cause of the degradation around the RPV head penetrations, and promptly meet with the NRC to discuss this information after you have reasonable confidence in your determination.
NRCs Status CAL Update 3-02-00 1 E, dated September 19,2003 (Log 1-4445):
This issue is closed.
CAL Update 3-02-001E stated, FENOC submitted its Root Cause Analysis Report of the RPV head degradation. The DBNPS Root Cause Analysis Report provided a broad scope assessment of the root cause, covering various programmatic, implementation and managerial issues, along with a description of the technical sequence of events from the initiation of cracking in the CRDM nozzles to the formation of the cavity. The staff reviewed the report and based on the information currently available, concluded that the analysis presents a plausible scenario of the degradation at the DBNPS. Uncertainties with regard to the technical details of the RPV head degradation preclude a definitive conclusion to the technical Root Cause Analysis Report. The level of understanding of the root cause is sufficient for the licensee to proceed with use of the replacement head from the Midland plant. FENOC also conducted seven individual assessments in the Management & Human Performance areas. These reports were reviewed as part of the NRCs Management and Human Performance special inspections. The overall assessment was of appropriate depth and breadth to develop actions to correct and prevent recurrence of the management and human performance deficiencies associated with the reactor head degradation.
FENOCs Action Section I11 of the Integrated Restart Report to Support Restart of the DBNPS (IRR), dated November 23,2003, (Serial Letter 1-1336) summarizes the root cause analyses performed for the degradation of the reactor vessel head and the failure to identify the degradation.
FENOC Submittal References Serial Letter 1-1270, dated April 18, 2002; Root Cause Analysis Report Regarding Reactor Serial Letter 1-1286, dated August 21,2002; Management and Human Performance Root Serial Letter 1-1289, dated September 23, 2002; Revision 1 to Root Cause Analysis Report Pressure Vessel Head Degradation Cause Analysis Report Regarding Reactor Pressure Vessel Head Degradation
Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1345, Page 4 of 9 FENOCs Status of Completion of the Restart Confirmatory Action Letter 3-02-001 Serial Letter 1-1299, dated January 9, 2003; Submittal of Root Cause Evaluations Root Cause Analysis of:
Quality Assurance Oversight; Root Cause Analysis of Operations; Assessment of Company Nuclear Review Board; Root Cause Analysis of Corrective Action Problem Resolution Human Performance and Implementation; Root Cause Analysis of Engineering Assessment Capabilities, and Evaluation of Corporate Management Serial Letter 1-1306, dated March 27,2003; Collective Significance Review of Causal Factors Associated with the RPV Head Degradation and Revision 2 of the Management and Human Performance Improvement Plan Assessment of Engineering Capabilities of the DBNPS and Request for Restart Approval Serial Letter 1-1314, dated May 2,2003; Submittal of Revision 1 of the Root Cause Serial Letter 1-1336, dated November 23, 2003; Integrated Restart Report to Support Restart
Docket Number 50-346 License Number NPF-3 Serial Number 1-1345, Page 5 of 9 FENOCs Status of Completion of the Restart Confirmatory Action Letter 3-02-001 Confirmatory Action Letter, Item 3 CAL Item Description Evaluate and disposition the extent of condition throughout the reactor coolant system relative to the degradation mechanisms that occurred on the RPV head.
NRCs Status CAL Update 3-02-001B, dated December 24,2002 (Log 1-4325):
CAL Update 3-02-001B stated, this CAL Item remains open pending additional NRC inspection of action regarding Inspection Report 2002-0 12 Unresolved Items and corrective actions for identified deficiencies.
FENOCs Action As discussed in Section IV.C.1 of the Integrated Restart Report, FENOC has performed inspections of the reactor coolant system to identify the extent of condition of Primary Water Stress Corrosion Cracking and boric acid corrosion. As concluded in the IRR, Davis-Besse has conducted comprehensive inspections and evaluations of the condition of S tructures, Systems and Components (SSC) within containment and has performed approximately 2,500 corrective actions. Davis-Besse concludes that the condition of SSCs within containment will support safe restart and operation.
Additionally, Serial Letter 1-1 338, documented resolution of the final three (3) Inspection Report 2002-012 Unresolved Items (URI) for this CAL Item. These Inspection Report URIs are:
2002-12-01, Potential Leakage at the Reactor Vessel Incore Penetration Tubes 2002-1 2-02, Potential Impact of Corrosion on the Ground Function of Electrical Conduit in Containment 2002-12-03, Potential Failure to Follow the Procedure for Raycheni Splice Removal on Since these three (3) Inspection Report URIs were inspected satisfactorily, FENOC requested closure of the three (3) URIs and CAL Item 3.
Electrical Cables FENOC Submittal References Serial Letter 1-1336, dated November 23, 2003; Integrated Restart Report to Support Restart Serial Letter 1-1338, November 26,2003; Closure of Confirmatory Action Letter Item 3 of the DBNPS and Request for Restart Approval
Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1345, Page 6 of 9 FENOCs Status of Completion of the Restart Confirmatory Action Letter 3-02-001 Confirmatory Action Letter, Item 4 CAL Item Description Obtain NRC review and approval of the repair or modification and testing plans for the existing RPV head, prior to implementation of those activities. Prior to restart of the reactor, obtain NRC review and approval of any modification and testing activity related to the reactor core or reactivity control systems. If the reactor vessel head is replaced in lieu of repair or modification, the replacement must comply with appropriate Commission rules and industry requirements.
NRCs Status CAL Update 3-02-001B, dated December 24,2002 (Log 1-4325):
CAL Update 3-02-001B stated, this CAL Item remains open pending NRC review of successful completion of the reactor coolant system pressure test and control rod drive performance test.
FENOCs Action As discussed in Section IV.B of the Integrated Restart Report, FENOC has replaced the RPV Head, and has performed inspections and tests of the new head. The Mode 3 pressure test completed in September 2003 has verified its acceptability. Also, as described in the body of this letter, the Control Rod insertion time testing was completed as the final action for this CAL Item.
FENOC Submittal References Serial Letter 1-1271, dated April 25, 2002; Partial Response to CAL 3-02-001 - Repair Plans Serial Letter 1-1281, dated August 9,2002, Replacement of the RPV Head at the DBNPS Serial Letter 1-1345, (this submittal); Closure of CAL Items 4 and 5 and Completion of for the DBNPS Reactor Pressure Vessel Head CAL 3-02-001
Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1 345, Page 7 of 9 FENOCs Status of Completion of the Restart Confirmatory Action Letter 3-02-001 Confirmatory Action Letter, Item 5 CAL Item Description Prior to the restart of the unit, meet with the NRC to obtain restart approval. During that meeting, we expect you will discuss your root cause determination, extent of condition evaluations, and corrective actions completed and planned to repair the damage and prevent recurrence.
NRCs Status CAL Update 3-02-001B, dated December 24,2002 (Log 1-4325):
CAL Update 3-02-001B stated, FENOC submitted Revision 3 of the DBNPS Return to Service Plan to the NRC on September 23, 2002. Upon completion of the restart actions described in this plan, FENOC will submit its Integrated Restart Report summarizing the root cause determination, extent of condition evaluations and corrective actions completed and planned to prevent recurrence. Prior to entering Mode 2, FENOC will meet with NRC to discuss completed and planned actions as described in this Plan and to provide justification for restart.
CAL Issue No. 5 remains open pending that meeting and NRC restart approval.
FENOCs Action Davis-Besse Serial Letters 1-1336 and 3026 submitted the DBNPS Integrated Restart Report and its Supplement. The Davis-Besse Integrated Restart Report, Serial Letter 1 - 1336, Section I11 and IV described the root cause analyses determinations, extent of condition evaluations and corrective actions completed and planned to prevent recurrence.
FENOC met with the NRC and discussed the RPV head degradation root causes, extent of condition and corrective actions and the DBNPS request for restart during a Public Meeting on February 12,2004.
FENOC Submittal References Serial Letter 1-1288, dated September 23,2002; DBNPS Return to Service Plan, Revision 3 Serial Letter 1-1310, dated April 6, 2003; DBNPS Return to Service Plan, Revision 6 Serial Letter 1-1336, dated November 23,2003; DBNPS Integrated Restart Report Serial Letter 3026, dated February 6, 2004; DBNPS Integrated Restart Report Supplement Serial Letter 1-1345, (this submittal); Closure of CAL Items 4 and 5 and Completion of CAL 3-02-001
Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1345, Page 8 of 9 FENOCs Status of Completion of the Restart Confirmatory Action Letter 3-02-001 Confirmatory Action Letter, Item 6 CAL Item Description Provide a plan and schedule to the NRC, within 15 days of the date of this letter, for completing and submitting to the NRC your ongoing assessment of the safety significance for the Reactor Pressure Vessel (RPV) head degradation.
NRCs Status CAL Update 3-02-00 1 B, dated December 24,2002 (Log 1-4325):
This issue is closed.
CAL Update 3-02-001B stated, FENOCs plan and schedule for completing and submitting the assessment of the safety significance of the RPV head degradation was submitted on March 27, 2002. FENOC submitted the Safety Significance Assessment to the NRC on April 8,2002 and responded to requests for additional information.
FENOCs Action FENOC provided the DBNPS plan and schedule for Safety Significance Assessment of Reactor Pressure Vessel Head Degradation to the NRC on March 27, 2002, via Serial Letter 1-1267. FENOC provided an analysis of the safety significance of the RPV head degradation on April 8,2002 (Serial Letter 1-1268) and provided the final examination report of the RPV Head Degradation, and updated the Safety Significance Assessment on August 13,2003 (Serial Letter 2968).
FENOC Submittal References Serial Letter 1-1267, dated March 27,2002; Plan and Schedule for Safety Significance Serial Letter 1-1268, dated April 8,2002; Safety Significance Assessment of the DBNPS Serial Letter 1 - 1277, dated June 12, 2002; Response to Request for Additional Information Serial Letter 1 - 1280, dated July 12,2002; Response to Request for Additional Information Assessment of Reactor Pressure Vessel Head Degradation Reactor Pressure Vessel Head Degradation Related to the DBNPS Safety Significance Assessment Related to the DBNPS Safety Significance Assessment
Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1 345, Page 9 of 9 FENOCs Status of Completion of the Restart Confirmatory Action Letter 3-02-001 Serial Letter 1 - 1282, dated July 20, 2002; Response to Request for Additional Information Serial Letter 2968, dated August 13, 2003; Transmittal of Final Report on Examination of the Serial Letter 1 - 1290, dated November 18,2002; Response to Request for Additional Related to the DBNPS Safety Significance Assessment Reactor Vessel Head Degradation, and Safety Significance Assessment Update Information Related to the DBNPS Safety Significance Assessment
Docket Number 50-346 License Number NPF-3 Serial Number 1 - 1345, Page 1 of 1 COMMITMENT LIST The following list identifies those actions committed to by the Davis-Besse Nuclear Power Station in this document. Any other actions discussed in the submittal represent intended or planned actions by The DBNPS. They are described only as information and are not regulatory commitments. Please notify the Manager - Regulatory Affairs (41 9-321-8450) of any questions regarding this document or associated regulatory commitments.
COMMITMENTS None DUE DATE N/A