ML081260190
| ML081260190 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/16/2008 |
| From: | Goodwin C Plant Licensing Branch III |
| To: | Allen B FirstEnergy Nuclear Operating Co |
| Wengert, Thomas NRR/DORL 415-4037 | |
| References | |
| GL-08-001, TAC MD7819 | |
| Download: ML081260190 (8) | |
Text
September 16, 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 - RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NO. MD7819)
Dear Mr. Allen:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated April 11, 2008 (ADAMS Accession No. ML081060396), FirstEnergy Nuclear Operating Company (the licensee) submitted a 3-month response to GL 2008-01 for Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS). The NRC staffs assessment of the responses for DBNPS is contained in the enclosure to this letter.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for DBNPS, with the exception of the clarifications and associated requests discussed in the enclosure, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the enclosure.
B. Allen If you have any questions regarding this letter, please feel free to contact me at (301) 415-3719.
Sincerely,
/RA/
Cameron S. Goodwin, Project Manager Plant Licensing Branch LPL3-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346
Enclosure:
As stated cc w/ encl: See next page
B. Allen If you have any questions regarding this letter, please feel free to contact me at (301) 415-3719.
Sincerely,
/RA/
Cameron S. Goodwin, Project Manager Plant Licensing Branch LPL3-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-346
Enclosure:
As stated cc w/ encl: See next page Distribution:
PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 RidsNrrPMDavisBesse RidsNrrLATHarris RidsAcrsAcnw&mMailCenter RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr RidsNrrDssSrxb SSun, NRR RidsNrrDpr DBeaulieu, NRR RidsNrrDss WLyon, DSS/SRXB ADAMS Accession Number: ML081260190 NRR-106 OFFICE LPL3-2/PM LPL3-2/LA DPR/PGCB/BC DSS/DD LPL3-2/BC NAME CGoodwin THarris MMurphy JWermeil RGibbs DATE 09/5/08 09/4/08 09/9/08 09/5/08 09/16/08 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 Lucas County Davis-Besse Nuclear Power Station One Government Center, Suite 800 Mail Stop A-DB-3065 Toledo, OH 43604-6506 5501 North State Route 2 Oak Harbor, OH 43449-9760 The Honorable Dennis J. Kucinich United States House of Representatives Director, Ohio Department of Commerce Washington, D.C. 20515 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 14400 Detroit Avenue Reynoldsburg, OH 43068-9009 Lakewood, OH 44107 Resident Inspector U.S. Nuclear Regulatory Commission Joseph J. Hagan 5503 North State Route 2 President and Chief Nuclear Officer Oak Harbor, OH 43449-9760 FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 Stephen Helmer 76 South Main Street Supervisor, Technical Support Section Akron, OH 44308 Bureau of Radiation Protection Ohio Department of Health David W. Jenkins, Attorney 35 East Chestnut Street, 7th Floor FirstEnergy Corporation Columbus, OH 43215 Mail Stop A-GO-15 76 South Main Street Carol OClaire, Chief, Radiological Branch Akron, OH 44308 Ohio Emergency Management Agency 2855 West Dublin Granville Road Danny L. Pace Columbus, OH 43235-2206 Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Zack A. Clayton Mail Stop A-GO-14 DERR 76 South Main Street Ohio Environmental Protection Agency Akron, OH 44308 P.O. Box 1049 Columbus, OH 43266-0149 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company State of Ohio - Transportation Department Mail Stop A-GO-2 Public Utilities Commission 76 South Main Street 180 East Broad Street Akron, OH 44308 Columbus, OH 43266-0573 Principal Assistant Attorney General Environmental Enforcement Section State Office Tower 30 East Broad Street, 25th Floor Columbus, OH 43215 President, Board of County Commissioners of Ottawa County Port Clinton, OH 43252
Davis-Besse Nuclear Power Station, Unit 1 cc: Paul A. Harden Vice President, Nuclear Support Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Mail Stop A-GO-2 76 South Main Street 76 South Main Street Akron, OH 44308 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 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
U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 DOCKET NO. 50-346
1. Background
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
- 2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081060396), FirstEnergy Nuclear Operating Company (the licensee) submitted a 3-month response to GL 2008-01 for Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS). The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because in-field verification of some segments of the subject system piping cannot be completed for the following reasons: (1) radiological dose due to entry into high radiation areas; (2) need to erect scaffolding (dose or adjacent equipment operability concerns); (3) prolonged containment vessel entries during power operation; and, (4) the need for removal of insulation from piping.
The licensee also stated that all evaluations of the as-built piping drawings will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an Enclosure
alternative course of action, the licensee plans to complete in-field verification of some segments of the subject system piping no later than restart from the next refueling outage, which is presently scheduled for first quarter 2010. The licensees letter dated April 11, 2008, listed the following commitment:
- 1. Any piping segments that are determined to need in-field verification, but have not received it prior to the 9-month GL 2008-01 response, will be in-field verified no later than restart from the next refueling outage currently scheduled for first quarter 2010.
The licensee stated that the alternative course of action is acceptable based on the following:
- 1. By the date of the 9-month response, the evaluations of the as-built piping drawings are planned to be complete, including reviews of the drawings for the piping segments that will not yet have received in-field verifications. The in-field verifications that will be completed after the 9-month response are intended to confirm the conclusions of those completed drawing evaluations.
- 2. By the date of the 9-month response, the evaluation of site procedures, which ensure the piping systems are sufficiently full of water to perform their function, is also planned to be complete.
Based on the above considerations, the licensee concluded that completing in-field verification of some segments of the subject system piping outside of the requested 9-month timeframe is an acceptable alternative course of action.
- 3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described procedure reviews and drawing reviews associated with managing gas accumulation at DBNPS.
The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, although the submittal states that any piping segments that are determined to need in-field verification, but have not received it prior to the 9-month GL 2008-01 response, will be in-field verified no later than restart from the next refueling outage currently scheduled for first quarter 2010, it is not clear if that is the date the information will be submitted to the NRC.
The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the DBNPS, first quarter 2010 refueling outage, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the first quarter 2010 refueling outage at DBNPS.
For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.