ML110700732

Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station-Section 2.2 & 2.3

ML110700732
Person / Time
Site:	Davis Besse
Issue date:	03/18/2011
From:	Harris B License Renewal Projects Branch 1
To:	Allen B FirstEnergy Nuclear Operating Co
Harris B, NRR/DLR, 415-2277
References
TAC ME4640
Download: ML110700732 (12)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 18, 2011 Barry S. Allen Vice President, Davis-Besse Nuclear Power Station FirstEnergy Nuclear Operating Company 5501 North State Route 2 Oak Harbor, OH 43449

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION - SECTION 2.2 & 2.3 (TAC NO. ME4640)

Dear Mr. Allen:

By letter dated August 27,2010, FirstEnergy Nuclear Operating Company, submitted an application pursuant to Title 10 of the Code of Federal Regulation Part 54 (10 CFR Part 54) for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station. The staff of the U.S. Nuclear Regulatory Commission (NRC or the staff) is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." During its review, the staff has identified areas where additional information is needed to complete the review .. The staff's requests for additional information are included in the Enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Cliff Custer, of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions.

please contact me by telephone at 301-415-2277 or bye-mail at brian.harris2@nrc.gov.

Sincerely,

//./ ~.~<~~tl*

/........... . .

Brian K. Harris, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION REVIEW 2.2 PLANT-LEVEL SCOPING RESULTS RAI2.2-1 License renewal application (LRA) Section 2.2, Tables 2.2-1, Table 2.2-2 and Table 2.2-3 provide the results of applying the license renewal scoping criteria to the systems, structures, and commodities. The license renewal scoping criteria was described in Section 2.1. The following updated safety analysis report (USAR) systems could not be located in LRA Tables 2.2-1 or 2.2-2.

USAR Section System 5.2.6 Loose Parts Monitoring Loose Parts Monitoring System 9.2.4.2 System Description Domestic Water System 10.4.8 Steam Generator Slow Down System Steam Generator Slowdown System 11.5 Solid Waste System Solid Waste System 9.1.4. Fuel Handling System Fuel Handling System The staff requests that the applicant justify its exclusion of the above systems in Tables 2.2-1, 2.2-2 or 2.2-3.

2.3 SCOPING AND SCREENING RESULTS: MECHANICAL SYSTEMS RAI2.3-01 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an aging management review (AMR) by reviewing the results of the screening of components within the license renewal boundary.

For the drawing locations identified in the table below, the continuation of piping in scope for license renewal could not be found.

License Renewal Application Continuation Issue i (LRA)Section I Drawing Number I

& Location

• 2.3.3.3 Auxiliary Steam and Station Heating System I LR-M021, Rev 1, F-14 & G-14 Valves SH528 & SH537 continuation drawings were not provided.

! LR-M021, Rev 1, F-13 & G-13 Valves SH331 & SH332 continuation drawings were not provided. I

~R-M021, Rev 1, F-12 & G-12 Valves SH30 & SH31 continuation drawings were not ENCLOSURE

-2 provided.

LR-M021, Rev 1, F-11 & G-11 Valves SH544 & SH520 continuation drawings were not provided.

LR-M021, Rev 1, F-9 Valves SH156 & SH157 continuation drawings were not provided.

LR-M021, Rev 1, F-8 Valves SH175 & SH176 continuation drawings were not provided.

2.3.3.11 Demineralized Water Storage System LR-M010C Rev. 0, K-10 and K-11 Continuation of 1"-HCO-37 overflow piping and 1"HCO 38 piping is not provided.

2.3.3.19 Makeup Water Treatment System Drawing LR-M011, Rev 0, A-8, 8-7 LR Note 1 and Note 7 indicate Station Plumbing and E-6 continues on drawings M-160, M-161 and M-192. These continuation drawings were not provided.

2.3.3.30 Station Blackout Diesel Generator System LR-M0170 Rev. 0, H-8 Continuation to the governor air booster pump is not provided.

2.3.3.31 Station Plumbing, Drains, and Sumps System M-041C, G-3, 7 & 10 Continuation of 4"-MSO-3 to containment normal sump is not provided.

2.3.4.1 Auxiliary Feedwater System LR-M0060, Rev 0, G-10 Valve AF2659 continuation drawings are not provided.

LR-M0060, Rev 0,G-12 Valves AF416A & AF4168 continuation drawings were not provided.

LR-M0060, Rev 0,H-12 Valves AF498A & AF4988 continuation drawings were not provided.

2.3.4.3 Main Feedwater System LR-M-0060, Rev 0, C-2 & G-4 Valves FW5885A & FW500A continuation drawings were not provided.

2.3.4.4 Main Steam System LR-M003A, Rev 0,8-2 & E-3 Valves IA566 & IA562 continuation drawings were not provided.

LR-M003A, Rev 0,0-7 & F-7 Valves MS210A & MS209A continuation drawings were not provided.

LR-M003C, Rev 1, E-11 & F-11 Valves MS2063 (MS2067) & MS2062 (MS2066) continuation drawings were not provided.

LR-M003C, Rev 1, H-5 & H-7 Valves MS58 & MS59 continuation drawings were not provided.

LR-M003C, Rev 1, K-5 Valves MS53 & MS54 continuation drawings were not provided.

LR-M003C, Rev 1, K-9 Valves MS51 & MS52 continuation drawings were not provided.

LR-M007A, Rev 0,0-6 & 0-9 Valves ICS11A8 & IS811 88 continuation drawings were not provided.

LR-M0078, Rev 1, 0-2 & 0-9 Valves IA 1008E & IA 1009E continuation drawings were not provided.

- 3 LR-M0078, Rev 1, 8-3 & 8-12 Valves FW26858, FW2685D, FW26868 & FW2686D continuation drawings were not provided.

I LR-M0078, Rev 1, 8-5 & 8-11 Valves AF6456A, AF64568, AF6457 A & AF64578 continuation drawings were not provided.

The staff requests the applicant to provide sufficient information to locate the license renewal boundary. If the continuation cannot be shown on license renewal boundary drawings, then provide additional information describing the extent of the scoping boundary and verify whether or not there are additional AMR component types between the continuation and the termination of the scoping boundary. If the scoping classification of a section of the piping changes over the continuation, provide additional information to clarify the change in scoping classification.

2.3.3 AUXILIARY SYSTEMS 2.3.3.4 Boron Recovery System RAI 2.3.3.4-01 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.

License renewal drawing LR-M0338, Rev 0, location G-8 shows a section of 10 CFR 54.4 (a)(2) piping (1"-HSC-18) continuing from drawing LR-M037D, location C-5 (from the Sodium Hydroxide Mix Tank) where it is not included in scope of license renewal.

The staff requests the applicant to provide additional information to clarify the scoping classification of this pipe section.

2.3.3.11 Demineralized Water Storage System RAI 2.3.3.11-01 In LRA Section 2.1 the applicant states that its screening process was used to identify the passive, long-lived structures and components in the scope of license renewal and subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

License renewal drawing LR-M010C Rev. 0, location K-11, shows a fluid level gage component that provides a pressure boundary function. This component type was not included in LRA Table 2.3.3-11, "Demineralized Water Storage System Components Subject to Aging Management Review."

The staff requests the applicant to justify the exclusion of the fluid level gage component type from LRA Table 2.3.3-11.

2.3.3.12 Emergency Diesel Generators System

-4 RAI 2.3.3.12-01 In LRA Section 2.1, the applicant states that its screening process was used to identify the passive, long-lived structures and components in the scope of license renewal and subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Drawings LR-OS041 A 1, location G-3, and LR-OS041 A2, locations G-21, show sight glass components as in scope for license renewal. At locations G-7 and G-25 on the same drawings, flow glass components are shown as in scope for license renewal. The sight glass and flow glass components perform a pressure boundary function but were not included in LRA Table 2.3.3-12, "Emergency Diesel Generator System Components Subject to Aging Management Review."

The staff requests the applicant to justify the exclusion of the sight glass and flow glass components from LRA Table 2.3.3-12.

2.3.3.18 Makeup and Purification System RAI 2.3.3.18-01 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.

License. renewal drawing LR-M031C, Rev 0, location 0-13, shows 10 CFR 54.4(a)(2) line 1W' HSC-61 continuing to drawing LR-M040A, location E-8, where it is shown as not in scope.

The staff requests the applicant to provide additional information to clarify the scoping classification of this pipe section.

2.3.3.19 Makeup Water Treatment System RAI 2.3.3.19-01 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.

License renewal drawing LR-M011, Rev 0, location C-7, shows a 6"-JEE line in scope for 10 CFR 54.4(a)(2). The license renewal boundary is shown to end at valve DM65 without an explanation for the scoping change. If the piping and components downstream of this point have not left a space containing components in scope for 10 CFR54.4(a)(1) then the scoping boundary for spatial interaction should not end.

The staff requests the applicant to justify its exclusion of the the piping and components upstream of valve DM65 from the scope of license renewal.

2.3.3.21 Miscellaneous Liquid Radwaste System

-5 RAI 2.3.3.21-01 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.

Drawing LR-M039A, Rev 1, location E-8, provides LR Note 8 which states "Components beyond the highlighting are in the Condensate Demineralizer system and are not within the scope of license renewal." The staff questions if the piping and components downstream of this point occupy a space containing components in scope for 10 CFR 50.4(a)(1) and therefore, would be required to be in scope for spatial interaction.

The staff requests the applicant to justify its exclusion of the components downstream of LR Note 8 from scope of license renewal.

RAI 2.3.3.21-02 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AIVIR by reviewing the results of the screening of components within the license renewal boundary.

Drawing LR-M0398, Rev 1, location E-3, downstream of valve WM142 provides LR Note 8 which states "Components beyond the highlighting are not in the scope of license renewaL" The staff questions if these components occupy a space containing components in scope for 10 CFR 50.4(a)(1) and would therefore be required to be in scope for spatial interaction.

The staff requests the applicant to justify its exclusion of the components downstream of valve WM142 from scope of license renewal.

RAI 2.3.3.21-03 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.

Drawing LR-M037C, Rev 0, location K-12, shows 1 W'-HSC-109 continued from drawing LR M037D as in scope. However, drawing LR-M037D, location C-1 shows this piping as not in scope.

The staff requests the applicant to provide additional information to clarify the scoping classification of this pipe section.

-6 2.3.3.22 Nitrogen Gas System RAI 2.3.3.22-01 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary .

. License renewal drawing LR-M019, Rev 0, locations E/F-14, and K-1, show electrical penetrations PIC 5SX, PIL 5WX and P2L 2CX as not in scope for license renewal. However similar electrical penetrations at locations A thru D-14 and E thru F-1 are shown as in scope for license renewal to the upstream check valve.

The staff requests the applicant to justify its exclusion of electrical penetrations PIC 5SX, PIL 5WX and P2L 2CX from the scope of license renewal.

2.3.3.25 Sampling System RAI 2.3.3.25-01 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.

License renewal drawing LR-M-042C, location E-2, shows line %" -HCC-112 continuing from drawing M-031 C, location C-4 as in scope for license renewal; however the same line is shown as not in scope on drawing LR-M-031C.

The staff requests the applicant to provide additional information to clarify the scoping classification of this pipe section.

RAI 2.3.3.25-02 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.

License renewal drawing LR-M-042B, Rev 0, location E-8, shows a sample line (sample No. S 039-6) as not in scope for license renewal. However, on drawing LR-M039B this sample line is shown as in scope for license renewal starting at location H-7 and returning at location E-4.

The staff requests the applicant to provide additional information to clarify the scoping classification of this pipe section.

-7 2.3.3.26 Service Water System RAI 2.3.3.26-01 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to an AMR by reviewing the results of the screening of components within the license renewal boundary.

On drawing LR-M041A, Rev. 0, location K-5, the continuation of 3/8" HBD piping from Dilution Pump P180 is shown in scope for license renewal. Contrary to the information in bullet 3 on Page 2.3-129 of the LRA, the 3/8" HBD piping is not shown as a rubber hose on drawing LR M041A.

The staff requests the applicant to provide clarification as to whether the 3/8" HBD line is pipe or rubber hose.

2.3.3.30 Station Blackout Diesel Generator System RAI 2.3.3.30-01 In LRA Section 2.1, the applicant states that its screening process was used to identify the passive, long-lived structures and components in the scope of license renewal and subject to an AMR. The staff confirms inclusion of all components subject to an AIVIR by reviewing component types within the license renewal boundary.

The applicant depicts on LRA drawing LR-M017D, Rev.O, location G-4 and J-4 an air dryer housing and at location E-10 an air intake vibration damper housing in scope of license renewal.

However, the air dryer and vibration damper housings were not included in LRA Table 2.3.3-30.

The staff requests the applicant to justify the exclusion of these housing components from LRA Table 2.3.3-30, "Station Blackout Diesel Generator System Components Subject to Aging Management Review."

RAI 2.3.3.30-02 In LRA Section 2.3.3.30 in the SBODG Jacket Water System on page 2.3-139 there is a discussion in paragraph four about two fans which start automatically to cool the radiator cooling coils when needed. The applicant stated "If the fans are out of service, and the SBODG must be run, most of the cooling can be provided by spraying water on the radiator coils. Engine load capacity in this case will have to be limited to prevent engine overheating depending on weather conditions. "

The spray system components for spraying water on the radiator coils are not identified in the LRA or in Chapter 8 of the USAR. It is not clear if these components are required to be in scope for license renewal.

The staff requests the applicant provide a description for the method for spraying down the radiator coils and clarify if the necessary components are in scope for license renewal.

- 8 RAI 2.3.3.30-03 In LRA Section 2.1, the applicant states that its screening process was used to identify the passive, long-lived structures and components in the scope of license renewal and subject to AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

On drawing LR-M017D, Rev. 0, location H-4 and K-4 there are check valves DA205 and D0204 respectively that are needed to maintain pressure in the air receiver tanks for the SBODG Air Start System. The 1-inch pipelines currently end the scoping boundary at manually operated, normally open ball valves DA207 and DA206 while check valves DA205 and DA204 are not included within the boundary. The check valves typically function to maintain air pressure in the air receiver tank. An example of check valves in scope on similar air receiver tanks is shown on LRA drawing LR-M017B, Rev. 0 at locations C-5, E-6, G-6 and J-5.

The staff requests the applicant to provide an explanation why the license renewal boundaries do not extend to the DA205 and DA204 check valves.

2.3.4 STEAM AND POWER CONVERSION SYSTEMS 2.3.4.1 Auxiliary Feedwater System RAI 2.3.4.1-01 In LRA Section 2.1, the applicant states that its screening process was used to identify the passive, long-lived structures and components in the scope of license renewal and subject to an AMR. The staff confirms inclusion of all components subject to an AIVIR by reviewing component types within the license renewal boundary.

Drawing LR-M006D, Rev. 0, location H-9, shows piping (6"-HBD-137) that is in scope for 10 CFR 54.4(a}(2) as non-safety piping attached to safety related piping. The scoping boundary ends at the limit of the Seismic Analysis (S/I flag), but it is not clear if the piping downstream of this point is still within the same space as the safety related components. The staff questions if this pipe line downstream of the SII interface is fluid filled and located in the vicinity of 10 CFR 54.4(a)(1) components.

The staff requests the applicant to provide sufficient information to verify that the not in scope piping is not located in an area with 10 CFR 54.4(a)(1) components.

2.3.4.3 Main Feedwater System RAI 2.3.4.3-01 In LRA Section 2.1, the applicant states that its screening process was used to identify the passive, long-lived structures and components in the scope of license renewal and subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

The applicant depicts on drawing LR-M006D, Rev 0, locations H-2, and C-14, drip rim drains below the Motor Driven Start-up Feed Pump 1-1, and Aux. Feed Pumps P14-1 and P14-2 as not in of scope. These drains may contain fluid and are apparently in an area that contains

-9 safety related components, in which case they would be included within the scope of license renewal under 10 CFR 54.4(a)(2).

The staff requests the applicant to provide additional information to explain why the drip rim drain and connected piping are not in scope.

2.3.4.4 Main Steam System RAI 2.3.4.4-01 In LRA Section 2.1, the applicant states that its screening process was used to identify the passive, long-lived structures and components in the scope of license renewal and subject to an AMR. The staff confirms inclusion of all components subject to an AIVIR by reviewing component types within the license renewal boundary.

The applicant depicts on drawing LR-M045, Rev 1, locations 0-12 and 0-14, piping to valves SC200 and SC201 from the to Steam Generator Wet Lay-Up Chemical Addition Tanks as not in scope. However, these tanks as well as additional piping lines connected to the tanks are shown as in scope for 10 CFR 54.4(a)(2).

The staff requests the applicant to justify its exclusion of the %" piping to valves SC200 and SC201 from the scope of license renewal.

RAI 2.3.4.4-02 In LRA Section 2.1, the applicant states that its screening process was used to identify the passive, long-lived structures and components in the scope of license renewal and subject to an AMR. The staff confirms inclusion of all components subject to an AMR by reviewing component types within the license renewal boundary.

Drawing LR-M-045, Rev 1, locations E-11 and E-13, shows anti-siphon devices downstream of the Steam Generator Wet Lay-Up Chemical Addition Metering Pumps 1-1 and 1-2 as not in scope. The piping to which these components are attached is in scope for 10 CFR 54.4(a)(2).

The staff requests the applicant to provide additional information to explain why the anti-siphon device is not in scope and not listed as a component type in LRA Table 2.3.4-4, "Main Steam System Components Subject to Aging Management Review."

ML110700732 OFFICE: LR PM:RPB1 :DLR BC:RPB1 :DLR PM:RPB1 :DLR NAME: IKing Harris BPham BHarris DATE: 3/16/11 117111 3/18/11 3/18/11 Letter to B. Allen from B. Harris Dated March 18, 2011

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION - SECTION 2.2 & 2.3 (TAC NO. ME4640)

HARDCOPY:

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