ML081210342

David-Besse, Unit 1 - Request for Additional Information Related to Measurement Uncertainty Recapture Power Uprate

ML081210342
Person / Time
Site:	Davis Besse
Issue date:	05/05/2008
From:	Thomas Wengert NRC/NRR/ADRO/DORL/LPLIII-2
To:	Allen B FirstEnergy Nuclear Operating Co
Wengert, Thomas J, NRR/DORL, 415-4037
References
TAC MD8326
Download: ML081210342 (6)

Text

May 5, 2008 Mr. Barry S. Allen Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE (TAC NO. MD8326)

Dear Mr. Allen:

By letter to the Nuclear Regulatory Commission (NRC) dated April 12, 2007, as supplemented by letters dated September 18, October 8, October 19, 2007, and January 15 (2 letters),

February 14, February 20, and March 12, 2008, FirstEnergy Nuclear Operating Company submitted a request to increase the maximum power level from 2772 megawatt thermal (MWt) to 2817 MWt, for the Davis-Besse Nuclear Power Station, Unit No. 1.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on May 1, 2008, it was agreed that you would provide a response within 14 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.

Sincerely,

/RA/

Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

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

May 5, 2008 Mr. Barry S. Allen Site Vice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO MEASUREMENT UNCERTAINTY RECAPTURE POWER UPRATE (TAC NO. MD8326)

Dear Mr. Allen:

By letter to the Nuclear Regulatory Commission (NRC) dated April 12, 2007, as supplemented by letters dated September 18, October 8, October 19, 2007, and January 15 (2 letters),

February 14, February 20, and March 12, 2008, FirstEnergy Nuclear Operating Company submitted a request to increase the maximum power level from 2772 megawatt thermal (MWt) to 2817 MWt, for the Davis-Besse Nuclear Power Station, Unit No. 1.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on May 1, 2008, it was agreed that you would provide a response within 14 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-4037.

Sincerely,

/RA/

Thomas J. Wengert, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

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

PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 RidsNrrPMTWengert RidsNrrLAEWhitt RidsAcrsAcnw&mMailCenter RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr RidsNrrDirsItsb CSchulten, NRR ADAMS Accession Number: ML081210342 OFFICE LPL3-2/PM LPL3-2/LA DIRS/ITS/BC LPL3-2/BC NAME TWengert EWhitt RElliot RGibbs DATE 5/2/08 5/5/08 5/5/08 5/2/08 OFFICIAL RECORD COPY

Davis-Besse Nuclear Power Station, Unit No. 1 cc:

Manager, Site Regulatory Compliance President, Board of County FirstEnergy Nuclear Operating Company Commissioners of Ottawa County Davis-Besse Nuclear Power Station Port Clinton, OH 43252 Mail Stop A-DB-3065 5501 North State Route 2 President, Board of County Oak Harbor, OH 43449-9760 Commissioners of Lucas County One Government Center, Suite 800 Director, Ohio Department of Commerce Toledo, OH 43604-6506 Division of Industrial Compliance Bureau of Operations & Maintenance The Honorable Dennis J. Kucinich 6606 Tussing Road United States House of Representatives P.O. Box 4009 Washington, D.C. 20515 Reynoldsburg, OH 43068-9009 Resident Inspector The Honorable Dennis J. Kucinich U.S. Nuclear Regulatory Commission United States House of Representatives 5503 North State Route 2 14400 Detroit Avenue Oak Harbor, OH 43449-9760 Lakewood, OH 44107 Stephen Helmer Joseph J. Hagan Supervisor, Technical Support Section President and Chief Nuclear Officer Bureau of Radiation Protection FirstEnergy Nuclear Operating Company Ohio Department of Health Mail Stop A-GO-19 35 East Chestnut Street, 7th Floor 76 South Main Street Columbus, OH 43215 Akron, OH 44308 Carol OClaire, Chief, Radiological Branch David W. Jenkins, Attorney Ohio Emergency Management Agency FirstEnergy Corporation 2855 West Dublin Granville Road Mail Stop A-GO-15 Columbus, OH 43235-2206 76 South Main Street Akron, OH 44308 Zack A. Clayton DERR Danny L. Pace Ohio Environmental Protection Agency Senior Vice President, Fleet Engineering P.O. Box 1049 FirstEnergy Nuclear Operating Company Columbus, OH 43266-0149 Mail Stop A-GO-14 76 South Main Street State of Ohio - Transportation Department Akron, OH 44308 Public Utilities Commission 180 East Broad Street Manager, Fleet Licensing Columbus, OH 43266-0573 FirstEnergy Nuclear Operating Company Mail Stop A-GO-276 Principal Assistant Attorney General South Main Street Environmental Enforcement Section Akron, OH 44308 State Office Tower 30 East Broad Street, 25th Floor Columbus, OH 43215

Davis-Besse Nuclear Power Station, Unit 1 cc:

Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 James H. Lash Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308

REQUEST FOR ADDITIONAL INFORMATION DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346 In reviewing FirstEnergy Nuclear Operating Company=s (FENOCs) submittal dated April 12, 2007, as supplemented by letters dated September 18, October 8, October 19, 2007, and January 15 (2 letters), February 14, February 20, and March 12, 2008, related to the license amendment request to increase the maximum power level from 2772 Mwt to 2817 Mwt, for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), the NRC staff has determined that the following information is needed in order to complete its review.

Request for Additional Information (RAI)

1) Describe how the change to the current technical specication (TS) requirement, proposed in FENOC letter dated February 20, 2008, to perform a daily heat balance in accordance with Table 4.3-1, Notation (2), as modified by Insert 2 on page 3/4 3-8, contains agreement criteria that is equivalent to the agreement criteria in NUREG-1430, Surveillance Requirement (SR) 3.3.1.2, or provide another means acceptable to the NRC staff for meeting the requirement of Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.36.

NUREG-1430, SR 3.3.1.2, Note 1 agreement criteria for adjusting the power range channel output to agree with the secondary calorimetric heat balance provides an acceptable means to the NRC staff for meeting the requirements of 10 CFR 50.36, to assure that limiting conditions for operation (LCOs) are met during facility operation. DBNPS TS LCOs require the Reactor Protection System (RPS) High Flux instrumentation in Table 3.3-1 on page 3/4 3-2 to be capable of performing its safety function in accordance with the TS definition of operability. DBNPS TS Table 4.3-1 on page 3/4 3-7 requires testing requirements to be performed to assure the High Flux instrument channels are operable.

When the High Flux instrument channel SRs are successfully performed, the LCO for the RPS High Flux function is met in accordance with 10 CFR 50.36. The NRC staff position for calorimetric SRs to demonstrate that the the LCO is met requires calorimetric agreement criteria in the SR to ensure the power range channel outputs are within established limits.

2) Reconcile the discrepancy in the DBNPS TS Table 2.2-1 on pages 2-5 and 2-6 regarding the application of Note

• for table Allowable values. Note

• specifies the values to be: Allowable Value for CHANNEL FUNCTIONAL TEST. The note is applied to the High Flux allowable values which are identified as not requiring a CHANNEL FUNCTIONAL TEST ("N.A.") in DBNPS TS Table 4.3-1 on page 3/4 3-7.

Enclosure

Background/Regulatory Basis

1) RAI Regulatory Basis - Regulations 10 CFR 50.36(d)(3) Surveillance requirements.

SRs are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

2) RAI Regulatory Basis - DBNPS TSs OPERABLE - OPERABILITY Definition 1.6 A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal and emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment, that are required for the system, subsystem, train, component or device to perform its function(s), are also capable of performing their related support function(s).

SURVEILLANCE REQUIREMENTS Specification 4.0.1 - SRs shall be applicable during the OPERATIONAL MODES or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement.

Specification 4.0.2 - Each Surveillance Requirement shall be performed within the specified time interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

Specification 4.0.3 - Failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by Specification 4.0.2, shall constitute noncompliance with the OPERABILITY requirements for a Limiting Condition for Operation (LCO), except as noted below.

If it is discovered that a Surveillance was not performed within its specified frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable ACTIONS must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable ACTIONS must be entered.

SRs do not have to be performed on inoperable equipment.

3) RAI Regulatory Basis - Standard TSs SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.1 ensures that Surveillances are performed to verify the OPERABILITY of systems and components, and that variables are within specified limits.