ML041100407

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E-mail from J. Hopkins to J. Grobe Regarding Review of FENOC Integrated Report to Support Restart of the Davis-Besse Nuclear Power Station and Supplement to Report
ML041100407
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 02/20/2004
From: Hopkins J
NRC/NRR/DLPM/LPD3
To: Grobe J
NRC/RGN-III
References
FOIA/PA-2004-0140
Download: ML041100407 (13)
v • d • e


Text

V:

February 20, 2004 MEMORANDUM TO: John A. Grobe, Chairman Davis-Besse Oversight Panel THRU: Anthony J. Mendiola, Chief IRA/

Project Directorate ill, Section 2 Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Jon B. Hopkins, Sr. Project Manager, Section 2 IRAI Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

REVIEW OF FENOC INTEGRATED REPORT TO SUPPORT RESTART OF THE DAVIS-BESSE NUCLEAR POWER STATION AND SUPPLEMENT TO REPORT I have reviewed FirstEnergy Nuclear Operating Company's (FENOC) Integrated Report To Support Restart of the Davis-Besse Nuclear Power Station" submitted by letter dated November 23, 2003, and the supplement to the report submitted by letter dated February 6, 2004. My review was performed In accordance with nine criteria (Attachment 3) approved by the Davis-Besse Oversight Panel.

In the November 2003 report, the licensee included uAppendix C - Remaining Major Actions for Restart," and In Attachment 3 of the supplement to the report, the licensee updated Appendix C as of January 30, 2004. From my review of the report and Its supplement, I have not identified any open Issues that may Impact restart readiness beyond those identified in the updated Appendix C (Attachment 1). I also spoke with the licensee and they confirmed that completion of the updated Appendix C open Issues Is being tracked. This review meets the first seven review criteria.

From my review, I found no statements concerning restart items needing NRC action other than those items listed in the Restart Checklist and the Confirmatory Action Letter. The licensee's summary of completion of Restart Checklist Items and Confirmatory Action Letter items is Included In Appendix B of the November 2003 report (Attachment 2). This review meets review Criterion 8.

Lastly, I did not Identify any errors that may need correction In the report or Its supplement.

This review meets review Criterion 9.

Based on my review discussed above, I conclude that the FENOC report of November 2003 as supplemented on February 6, 2004, does not raise new Issues that could require NRC review prior to restart. This review was discussed with and accepted by the Oversight Panel on February 13, 2004.

Attachments: 1. Updated Appendix C

2. Appendix B
3. Review Criteria

February 20, 2004 MEMORANDUM TO: John A. Grobe, Chairman Davis-Besse Oversight Panel THRU: Anthony J. Mendiola, Chief IRA/

Project Directorate 111,Section 2 Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Jon B. Hopkins, Sr. Project Manager, Section 2 IRAI Project Directorate Ill Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

REVIEW OF FENOC INTEGRATED REPORT TO SUPPORT RESTART OF THE DAVIS-BESSE NUCLEAR POWER STATION AND SUPPLEMENT TO REPORT I have reviewed FirstEnergy Nuclear Operating Company's (FENOC) integrated Report To Support Restart of the Davis-Besse Nuclear Power Station" submitted by letter dated November 23, 2003, and the supplement to the report submitted by letter dated February 6, 2004. My review was performed in accordance with nine criteria (Attachment 3) approved by the Davis-Besse Oversight Panel.

In the November 2003 report, the licensee included "Appendix C - Remaining Major Actions for Restart," and InAttachment 3 of the supplement to the report, the licensee updated Appendix C as of January 30, 2004. From my review of the report and its supplement, I have not Identified any open Issues that may impact restart readiness beyond those Identified in the updated Appendix C (Attachment 1). I also spoke with the licensee and they confirmed that completion of the updated Appendix C open Issues is being tracked. This review meets the first seven review criteria.

From my review, I found no statements concerning restart Kiems needing NRC action other than those Items listed In the Restart Checklist and the Confirmatory Action Letter. The licensee's summary of completion of Restart Checklist Items and Confirmatory Action Letter items is Included InAppendix B of the November 2003 report (Attachment 2). This review meets review Criterion 8.

Lastly, I did not Identify any errors that may need correction Inthe report or Its supplement.

This review meets review Criterion 9.

Based on my review discussed above, I conclude that the FENOC report of November 2003 as supplemented on February 6, 2004, does not raise new Issues that could require NRC review prior to restart. This review was discussed with and accepted by the Oversight Panel on February 13, 2004.

Attachments: 1. Updated Appendix C

2. Appendix B
3. Review Criteria ADAMS Accession Number: ML040500360 (Package)

ADAMS Accession Number: ML040500188 (Memo)

ADAMS Accession Number: ML (Attachments I & 2)

OFFICE LA:PDIII-2 PM:PDIII-2 PDIII-2S/C NAME PCoates JHopkins AMendiola DATE 02119104 02/19/04 102120104 OFFICIAL RECORD COPY

. Remaining Major Actions for Restart Remainng Major Actions for Restart (Appendix CUpdate)

As of Januay 30, 2004, fth following are the principal actions that remain to be completed prior to restart.

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1. _Insl _nd test thcpumps.s
2. Clean, readjust packeng, or evaluate leakage as needed to correct No conditions Identified during the NOP tst.
3. Complete implementation of the electrical breaker coordination Yes modifications.
4. Perfoum operbilityevaluation ofCAC pressure transient issues to Yes support retart.

S. Complete implementation offthc restart-required actions in the Operations Improvement Implementation Action Plan and related improvements, as summarized in Section V.C. Remaining actions include:

  • Complete evaluation and remedial actions for Operator desanding of standards and expectations. Yes
  • Complete assessment and validation of key administrative procedures. Yes
  • Complete tining of Operatos an cifya*Operators are ready to return to Operaions. No
  • Place Operations Oversight Managers on hift. Yes
  • EhanceNQA with non-Davis-Besse personnel, and perform NQA monitoring of frmulator training cffctivcness. Yes Provide oversight monitoring and coaching. Yes
  • Perform an assessment of Operator performance by the Operations OversightManagers. Yes
  • Taining will be provided to site managers on performing maagement observans of Operations. Yes 3 1 3Attachment I

> .- _-.-'RemalningMs30rActionsforRcstart

6. COmplete rstart aions to improve parcat caUse eCaluions, as No summarized InSection VAL5 of Integrated Restart Report. Remaining actions Include:
  • Condition Report Analysts wbitin each section will receive strengthenedroles and responsibilities wi&t respect to apparent cause analyses. They will receie the same trainig as Apparent Cause evaluators, and will attend CARB meetings to enhance thei standards for review and acceptance of apparent cause analysis.
7. A process ownercilitator will be Identified to improve the consistency Yes of problem solving and decision-nakin
8. Restart Oversight Panel (ROP) Company Nuciar Review Board No (CNRB), and NQA vill make conclusions regarding the readiness of Davis-Bessc to restart. ROP and CNRE bavemade theirrestart rcommedations; NQA will make Its restart recommendation at Mode 2.
9. Complete the Restart Readiness Reviews for The second Mode 4 and No Mode 2. (Mode 4 reviews are complete) 1O. Adjust the RCS Integrated Lekag Program to accouit for 1he results of No the NOP test.
11. Complete evaluation ofservice wate flow balancing Issue and Identify No and schedule corrective actions.
12. Complete modification for Class 1E motor current overloads. No
13. Complete Electrical Transient Analysis Program Calculations and tap Yes ting.
14. Train site personnel on proper procedure compliance prior to restart. Yes 1S. Perform control rod drop surveillances when the plant returns to Mode 3. No
16. he Tecimical Specification template will be upgraded prior to restart to Yes require Improved logging ofthe detais of the action statements, including time due and task owner.

3 -2

Appendix B Matrix DemonstraUng Davis-Besse's Satisfaction of Criteria in NRC's Restart Checkdist A _uad cy of Root Cause Determinations l.n Penetration Cracking As discussed InSection MIA, Davis. NRC Integrated and Reactor Pressure Besse has completed root cause Inspection Report Vessel Corrosion analyses of the corrosion of the RPV 50-34603-04 head.

lb Organizational, As discussed in Section 1.B, Davis- NRC Special Programmatic and Besse has completed root cause Inspection Report Human Performance analyses of the organizational, 2002018 Issues programmatic and human performance Issued.

2 Adequacy of Safety Significant Structures, Systems, and Components 2,a Reactor Pressu Vessel As discussed in Section IV.B, Davis- Open Head Replacement Besse has installed and tested a new reactor vessel head.

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2.b Containment Vessel As discussed InSection V.B, Davis- NRC Inspection Restoration Following Besse has restored and tested the Report 50-346103-05 Reactor Pressure Vessel containment vessel.

. Head Replacement 2.c Structures, Systems, and As discussed in Section IV.CI, NRC Inspection Components Inside Davis-Besseias perfonmed Report (to be Issued)

. Containment inspections inside the containment to determine the extent of condition of PWSCC and boric acid corrosion, and has taken corrective action for degraded components as appropriate.

Less than five restart corrective actions remain open.

2.c.l Emergency Core As discussed in Section IVJ, Davis- NRC Inspection Cooling System and Besse has modified the containment Report 50-346103-17 Containment Spray emergency sump to cormet existing System Sump conditions and add safety margin.

2.d Extent-of-Condition of As discussed in Section VY, Davis- NRC Inspection Boric Add in Systems Besse has perfonmed Inspections Report 50-346103-22 Outside Containment outside the containment to determine (to be issued) the extent of condition of PWSCC and boric acid conosion, and has taken corctivc action for degraded components as appropriate.

Attachment 2

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Appendix B 2.c High Pressure Injection As discussed in Section IVE, Davis- Open Pump Internal Besse has performed tests and is ClemranceJDebris Installing and testing modified HPI Resolution pumps to ensure that they can perform their functions under deslgn basis debris loading conditions. The testing results and modification plans were discussed vith te NRC in a meeting on October21, 2003 (Log 6131).

3 Ad euacy of Safety Significant Program 3.a Corrective Action As discussed in Sections IVD Davis- Open Program Besse has reviewed and improved Its Co ive Action Program.

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3b OperatingExperience As discussed in Section IV.D. Davis- NRC Inspection Program Besse has reviewed and improved its Report 50-346103-09 Operaing xcerjencc Progm._

3.c Quality Audits and Self- As discussed InSection IVY), Davis- NRC Inspection Assessments of Besse has reviewed and Improved Its Report 50-346/03-23 Programs quality audit and self-assessment (to be issued) proMs.

3.d Boric Acid Corrosion As discussed in Section IVAD, Davis- NRC Inspection Management Program Besse has reviewed and Improved its Report 50-346103-17 Boric Acid Corrosion Control

_ _ _ __ _ _ _ rogro am.

3.e Reactor Coolant System As discussed InSection IVD, Davis- NRC Inspection Unidentified Leakage Besse has reviewed and Improved Its Report 50-346103-09 Monitoring Program Reactor Coolant Leakagc Monitoring Program.

  • 3.f In-Service Inspection As discussed InSection IVD, Davis- NRC Inspection Program Besse has reviewed and Improved its Report 50-346103-09 Inservice Inspection Program.

3.g Modification Control As discussed in Section IVi) Davis- NRC Inspection Program Besse has reviewed and Improved Its Report 50-346103-09 modification control program.

3b Radiation Protection As discussed in Section IV.D, Davis- NRC Inspection Program Besse has reviewed and improved its Report 50-346103-17 Radiation Protection promam.

B -2

Appendix B 3.1 Process for Ensuring As discussed InSection IVJ, Davis- NRC Inspection Completeness and Besse has taken action to improve the Report 50-346J03-19 Accuracy of Required completeness and accuracy of (to be Issued)

Records and Submittals required records and submittals to the to the NRC- NRC, and has pirformed an ectent of condition review of previous NRC submittals.

4 Adequacy or Or anizatlonal Effectiveness and Human Performance 4.a Adequacy of Corrective As discussed in Section V, Davis- NRC Special Action Plan Besse has established and Inspection Report Implemented a Management and 2002018 Human Performance Improvement Plan. Additionally, as discussed in Sections MIE and W1,P Davis-Besse has performed an Independent effectiveness review of Engineering, and has performed Functional Area Reviews of several other site organizations.

4.b Effectiveness of As discussed in Sections V.A and Open Corrective Actions YB, Davis-Besse has demonstrated the effectiveness of Its Management and Human Performance Improvement Plan. Davis-Besse has established and is implementing an Operations Improvement Action Plan to improve performance of Operations, and will be monitoring the improvements to ensure their

. _ effectiveness prior to restart.

5 Readiness for Restart 5.a Review of Ucensee's As discussed In Section IVYM, Davis- NRC Inspection Restart Action Plan Besse has Issued a Restart Action Report 50-346103-22 Plan, and NQA has performed (to be issued) assessments to verify the adequacy of restart processes and categorization of restart items.

B-3

Appendix B As discussed InSection IYE, Davis- I Restart Besse has performed a System Health Assurance Plan and has generated CRs for adverse conditions. As discussed In Section IVH, Davis-Besse has performed restart readiness reviews for Modes 6 and first Mode 4, and will be performing similar reviews before entry into the second 4.

Mode 4 andMode 2. .4 Operations Readiness As discussed in Section V.A, Davis- Open forRestart Besse has performed restart readiness I

reviews for Modes 6 and first Mode

4. and will be performing similar reviews before entry into the second Mode 4 and Mode 2. Additionally, as discussed in Sections V.B and V.C, Davis-Besse has performed an Integrated assessment of operational readiness during the NOP test, and is taldng corrective actions for the issues identified during the assessment.

S.d TestProgram As discussed InSection IV.G, Davis- Open Development and Besse has developed and Implementation implemented a Restart Tcst Plan.

Additionally, as discussed InSection WIB. Davis-Besse has performed a containment Integrated leak rate test, and aNOP test of the reactor coolant system to check-for leakage (including visual Inspection of the in-core nozzles in the bottom of the reactor vessel).

6 I~censing Issue Resolution 6.a Verification that Relief Davis-Besse submitted this RRs AS and A12 Requests AS and A12 verification by letter Serial Number approved by NRC in regarding the Shell to 1-1281 on August 9. 2002. letter dated Flange Weld (previously December 30, 2002 submitted by letter dated (NRC Inspection September 19, 200) Is Report 50-346103-not Impacted by the 04)

. idland RPV Head B-4

Appendlx B

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6.b American Society of Davis-Besse submitted the request on RRs A26 and A27 Mechanical Engineers August 1,2002, in letter Serial 2797 approved by NRC In (ASME) Code Relief and on September 23, 2002 in letter letter dated Request forPailure to Serial Number 2809. December 13,2002 Maintain Original (NRC Inspecton Radiographic Tests of Report 50-346/03-the Midland Head to 04, Log 6037)

Flange Weld (Planned Relief Request A26) 6s ASME Code Relief Davis-Besse submitted the request on RRs A26 and A27 Request for Inability to August 1, 2002, in letter Serial 2797 approved by NRC In RadiographicallyTest and on September 23, 2002 Inletter letter dated 100% of the Midland Serial Number 2809. December 13,2002 Reactor Pressure Vessel (NRC Inspection Head to Flange Weld Report 50-346/03-(Relief Request A27) 04, Log 6037) 6.d ResubmitRelief Davis-Besse submitted the equest on RR A2 approved by Request A2 (previously August 1, 2002, in letter Serial 2798. NRC in letter dated submitted by letter dated December 17,2002 September 19,2000) for (Log 6038)

I ASME Code for Inability to Perform 100% volumetric and surface examination of Read to Flange Weld I 6e Reconciliation Letter Davis-Besse submitted ihis letter, NRC found the that Demonstrates How Serial 1-1281, on August 9,2002. reconciliation tobe I

the New Reactor satisfactory in Pressure Vessel Head Inspection Report Correlates With the 50-346/03-04 ASME Code and QA Index for Section III and Section Xl -

Commitments 61 Verification Letter of Davis-Besse submitted this letter, NRC found the Technical Specification Serial 1-1285, on January22, 2003. reconciliation to be Pressure/Temperature satisfactory in Curves for New Vessel Inspection Report Head - Commitment 50-346103-04, dated May 9.2003 B-5

AppendixlB w .EiiW l4.

6.g Request to relocate High Davis-Bessc atbmitted this request NRC issued the Pressure Injection and Low Pressure Injection Subsystems Plow Balance Testing from Technical Specifications

  • 4.S.2.hto Updated Serial 2949, on May 21, 2003. amendment on August 12,2003 (Log 6110) I.3.

Safety Analysis Report Technical Requirements i1 Manual 7 Confirmatory Action Letter Resolution 7.a Verification that Davis-Besse has completed the Open

. Confirmatory Action actions Inthe CAL Davis-Besse will LUtter Items wre arange with NRC for a public Resolved, Including a meeting to discuss readiness to Public Meeting to restU Discuss Readiness for Restart .

B 6

Appendix B Matrix Demonstrating Davls-Besse's Satisfaction of Criteria In NRC's Confirmatory Action Letter tt Quarantine components or Davis-Besse quarantined the As discussed in a other material from the degraded reactor vessel head, cut letr from the NRC RPV head and CRDM samples of the areas of degradation dated September 19, nozzle penetrations tht for further data, and shipped those 2003, this item is are deemed necessary to samples to laboratory for analysis. closed.

fully address the root This analysis was completed and a cause of the occurrence of report provided to the NRC.

degradation of the leaking penetrations. Prior to implementation, plans for further inspection and data gathering to support determination of the mot cause will be provided to the NRC for review and comment. _

2. Determine the root cause As discussed in Section M, Davis- As discussed in a of the degradation around Besse has performed root cause letter from the NRC the RPV head analyses of the degradation of the dated September 19, penetrations, and reactor vessel head and the failure to 2003, this Item is promptly weet with the Identify the degradation. closed.

NRC todiscuss this information after you have reasonable confidence in Your determination. .

3. Evaluate and disposition As discussed in Section IV.C.1, Open the extent of condition Davis-Bcsse has performed throughout the reactor inspectons of the reactor coolant coolant system relative to system to identify the extent of the degradation condition of PWSCC and boric acid mechanisms that occurd corrosion.

on the RPV head.

B-7

Appendix B

4. Obtain NRC review and As discussed in Scetion IV.B, Davis- Open approval of the repair or Besse has replaced the reactor vessel modification and testing head, and has performed inspections plans for the existing RPV and tests of the new head and has head, prior to verified Its acceptability.

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 reactivlty 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.

5. Prior to the restart of.the Davis-Besse and NRC are arranging Open unit, meet with the NRC for this meeting. One of the purposes to obtain restart approval. of thls report is to support the During that meeting, we discussions at that meeting.

expect you will discuss your root cabse determination, extent of condition evaluations, and corrective actions completed and planned to repair the damage and Prevent recurrence.

6. Piovide a plan and Davis-Besse provided the plan and As discussed in a schedule to the NRC, schedule to the NRC on March 27, letter from the NRC within 15 days of the date 2002 (Serial 1-1267). Davis-Besse dated April 5,2002 of this letter, for provided an analysis of the safety (Log 1-4251), this completing and submitting sgnificance of the head degradation item is closed.

to the NRC your ongoing on April 8, 2002 (Serial 1-1268) and assessment of the safety August 13, 203 (Serial 2968).

significance for the RPV head degradation.

B-8

NRC EVALUATION CRITERIA DAVIS-BESSE NPS FENOC INTEGRATED REPORT TO SUPPORT RESTART INCLUDING SUPPLEMENT TO REPORT

1. Assess report discussion of licensee root cause analyses. Identify any open issues that may Impact restart readiness.
2. Assess report discussion of the Return to Service Plan and the seven building blocks.

Identify any open issues that may Impact restart readiness.

3. Assess report discussion of corrective action plans including long-term activities.

Identify any open Issues that may Impact restart readiness.

4. Review report discussion of Restart Checklist Items. Assess report discussion especially with regard to any pending licensee action. Identify any open Issues that may Impact restart readiness.
5. Assess supplemental report discussion of the Management and Human Performance Team Inspection exit meeting Issues of December 19, 2003. Identify any open issues that may Impact restart readiness.
6. Assess the supplemental report discussion of the Restart Readiness Team Inspection exit meeting Issues of December 19, 2003. Identify any open Issues that may Impact restart readiness.
7. Review report for licensee open Items needing closure prior to restart. Identify any open restart Items not tracked by the NRC Oversight Panel.
8. Review report for open items needing closure prior to restart that the report Identifies as needing NRC action. Develop a list of such report statements.
9. Review report for errors that may need correction In the public record. Develop a list of such errors.

February 2004 ATTACHMENT 3

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