ML19256E032
| ML19256E032 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/23/1979 |
| From: | Roe L TOLEDO EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| TAC-12453, NUDOCS 7910250325 | |
| Download: ML19256E032 (14) | |
Text
i e
Docket No. 50-346 roteco EDISON License No. NPF-3 Serial No. 546 LOWELL E. RCE October 23, 1979
[' 7"j'",'_
1419) 259-5242 Director of Nuclear Reactor Regulation Attention:
Mr. Darrell G. Eisenhut, Acting Director Division of Operating Reactors United States Nuclear Regulatory Commission Washington, D. C. 20555
Dear Mr. Eisenhut:
Toledo Edison has been engaged since March with other utilities and Babcock and Wilcox in an intense effort to provide added ass irance that our nuclear facilities are adequately designed and operated so that there is no undue risk to public health and safety. We consider that the actions we have taken since the TMI-2 event in areas of station operations and design have provided this added increment of assurance.
It is recognized that enhancements can be made in the areas of design, operations and emergency planning that can add an additional level of confidence to the already high margin of safety available. Numerous of these enhancements are subjects in your September 13, 1979 letter.
Your September 13, 1979 letter sets forth new regulatory positions on a wide variety of issues that have been under mutual review for several months. The anticipated NRC staff review and implementation procedures for these positions were delineated at the regional meetings the week of September 24, 1979. Additional technical detail on the NRC staff's positions was also provided at these meetings. Further definition was provided for a limited number of issues in the topical meetings with your staf f as recent as October 10, 11 and 12.
'Ihese documents and meetings have contributed much to our understanding of the staff's positions, directions and administration of post TMI-2 regulatory implementation. Additionally, they have brought forth the need to provide for a more flexible and, realistic implementation schedule.
We have been intensively involved with our NSSS Owners Groups, vendors, architect engineers and other consultants concerning implementation feasibility and schedule.
Attached, as a part of this letter, is our current assessment of the issues in your September 13, 1979 letter.
In some areas, the existing station design already con-forms to the NRC staff position.
In a few areas, alternate means are identified to meet a staf f position. There have been some areas identified where the requirements are beyond the state-of-the-art capability for equipment.
These and other technical discussions are included in the attachment.
h.
0
$4 t
i
- e. W 1 i
1210 340 ep O
6 z010250 O G THE TOLECO EDISLN CCMPANY ECISCN PLAZA 300 MACISCN AVENUE TCLE.. CHIO 43S52' F
i
Docket No. 50-346 License No. NPF-3 Serial No. 546 October 23, 1979 Page Two The implementation schedule dates included provide our current assessment of what is realistically achievable.
This schedule does not include any significant contingency for extended reviews, shortage of qualified hardware and equipment, or construction and installation problems. Consideration of these factors will require some additional flexibility.
Toledo Edison feels that with the established design of the Davis-Besse Station, which meets most of the current new design requirements, and with the modifications and procedural changes made in recent months, the implementation of these positions can proceed on the flexible schedule outlined without any adverse impact on the health and safety of the public.
We are proceeding with this major undertaking and will continue to expedite and improve on schedules if possible. We are available at your convenience to review any aspect.
Very truly yours, o*
ff.Y?
d{ /
a LER:TJM
\\2\\"u k\\
e Docket No. 50-346 License No. NPF-3 Serial No. 546 October 23, 19 79 TOLEDO EDISON RESPONSE TO NRC DIRECTOR OF OPERATING REACTORS LETTER OF SEPTEMBER 13, 1979 FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 (DB-1) 1210 342
l Toledo Edison Response to NRC Letter Dated September 13, 1979 NOTES:
- 1) All schedule dates are preliminary projections and subject to change based on outcome of reviews under 10CFR50.59, hardware availability and support manpower availability.
2)
Items in the attachment correspond to the identification schemes of the September 13, 1979 NRC letter and NUREG 0578. Task number designa-tions are for administrative cross-referencing within Toledo Edison.
I.
Letter Items:
Item a The staff vill be proposing a new rule on a Limiting Condition of Operation to require plant shutdown for certain human or procedural errors, particularly those which are repetitive in nature.
As such, no action is required on your part at this time.
(Task No. 36)
Response
No response required.
Item b At the present time we are delaying efforts regarding proposed rulemaking on both the inerting requirements for Mark I and II BWR containments, and the requirements regarding hydrogen recombiner capability; accordingly, no action is required on your part at this time.
(Task No. 14)
Response
No response required.
Item c The ACRS comments on the shift technical advisor have resulted in our assessment of the possible means of achieving the two functions which the Task Force intended to provide by this requirement.
The two functions are accident assessment and operating experience assessment by people on-site with engineering competence and certain other characteristics. We have concluded that the shif t technical advisor concept is the preferable short-term method of supplying these functions.
We have also concluded that some flexibility in implementation may yield the desired results if there is management innovation by individual licensees. We have prepared a statement of functional characteristics for the shif t technical advisor that will be used by the staff in the review of any alternatives proposed by licensees.
(Task No. 31)
Response
1210 343 See response to Section 2.2.1.b of Item f.
s Item d Three additional instrumentation requirements for short-term action were developed during the ACRS review of NUREG 0578. These items relate to containment pressure, containment water level and containment hydrogen monitors designed to follow the cours: of an accident.
(Task Nos. 37 - 39)
Response
CONIAINMENT PRESSURE - Safety grade control room indication for an extended range of containment vessel pressure will be provided at Davis-Besse Unit 1.
The current projected schedule identifies installation during the Spring 1981 refueling outage.
00NTAINMENT WATER LEVEL - Safety grade control room indication of narrow and wide range containment water level will be provided at Davis-Besse Unit 1.
The current projected schedule identifies installation during the Spring 1981 refueling outage.
CONTAINMENT HYDROGEN - Safety grade control room indication of ') - 10% hydrogen concentration will be provided at Davis-Besse Unit 1.
The currant projected schedule identifies installation b'y August 1981 Item e An additional requirement following issuance of NUREG 0578, which concerned a remotely operable high point vent for gas from the reactor coolant system, was developed (high point and vessel head vents, Task No. 40)
Response
A generic design effort is underway by B&W to provide a functional description of the construction, location, size and appropriate power supply for reactor coolant system high point vents. Appropriate safety analyses and reviews considering the effects of such vents are also being pursued concurrently.
It is presently projected that this design effort should be completed and forwarded to you for review and approval in January 1980.
Provided the evaluations are completed as expected and no potential unreviewed safety issues are identified, these vents could be installed during the planned Spring outage of 1981.
This is contingent upon NRC approval and qualified equip-ment availability within the time frame between NRC approval and the 1981 outage.
Item f NUREG 0578 recommendations as modified by the errata of Enclosure 5.
(Note that recommendations are numbered consistent with NUREG 0578).
Recommendation 2.1.1 - Emergency Power Supply Requirements for Pressurizer Heaters, Power Operated Relief Valves and Block Valves, and Pressurizer Level Indicators in PWRs.
(Task No. 001 - 005) 1210 344 Res ponse PRESSdRIZER HEATERS - The current Davis-Besse design provides manual loading of 126 kw of pressurizar heater capacity to each emergency diesel. Procedures are already in place covering the manual loading of these electrical loads. Davis-Besse currently meets this recommendation. No further action is required.
PILOT OPERATED RELIEF VALVE (PORV) - The current Davis-Besse design has its non-safety related pilot operated relief valve powered from a 125 vde bus supplied by a safety grade battery system.
Position indication is from the station un-Laerruptible power supply.
Davis-Besse meets the emergency power recommendation.
No further action is required.
PILOT OPERATED RELIEF VALVE BLOCK VALVES - Davis-Besse will provide a safety grade motive and control power source to the PORV block valve.
The power source will be appropriately isolated from non-safety grade partions of the system. Pending acceptability of the safety review and equipment availability an emergency source will provide power to the PORV block valve prior to startup af ter the next refuel-ing outage scheduled for March 1980.
PRESSURIZER LEVEL INDICATORS - The current Davis-Besse design has two channels of safety grade pressurizer level indication on a safety grade power supply.
Davis-Besse currently meets this recommendation. No further action is required.
Recommendation 2.1.2 - Performance Testing for BWR and PWR Relief and Safety Valves. (Task No. 6)
Response
The EPRI/NSAC effort to conduct performance testing of pressurized water reactor relief and safety valves is cur cently in its program definition state. When de-fLaed, we will verify that the program is applicable to Davis-Besse. The current EPRI/NSAC plans are to generically review the program with the NRC prior to testing thus ensuring the applicability of the test to the NRC staff recommendation.
Toledo Edison's understanding of the current projected schedule is to provide substantive test data by July, 1981. However, scheduling of the test f acility, f acility modification, valve acquisition and the possibility of extensive retest-ing could result in delays.
Recommendation 2.1. 3.a - Direct Indication of Power Operated Relief Valve and Safety Valve Position for PWRs and BWRs. (Task No. 7)
Response
Toledo Edison will provide positive primary system' safety valve and PORV position indication by the use of an acoustic monitoring system.
Discussions with vendors supplying these devices indicate that the system can be powered f rom a safety related power supply with sensors that are seismically and environmentally qualified.
However, the entire system will not meet safety grade requirements. Current g lans are to have this system operable in April,1980.
Toledo Edison considers this system will satisfy the recommendation.
1210 345 Recommendation 2.1. 3.b - Instrumentation for Detection of Inadequate Core Cooling in BWRs and PWRs.
(Task Nos. 8 - 10).
Response
Toledo Edison is participating with B&W in the development of procedural guide-lines for operator recognition of inadequate core cooling under the conditions identified in Section 3 of recommendation 2.1.9 (NUREG 0578, page A-44).
The current schedule projects guideline availability to be incorporated into Davis-Besse procedures in Ma.ch, 1980.
The design of any new instrumentation, if deemed necessary by a joint B&W Owners evaluation, would be submitted for NRC review and approval in April 1980. A scheduled installation date for any such instrumentation will be provided along with the April 1980 proposal.
DB-1 will install safety grade primary coolant saturation meters which will pro-vide on-line control room indication of coolant saturation condition. The degree of safety grade temperature inputs available is currently under review. The projected schedule for system installation is in July 1980.
This may not incluie all safety grade input signals.
Recommendation 2.1.4. - Containment Isolation Provision for PWRs and BWRs (Task Nos. 11 & 12).
Response
The current DB-1 design censes diverse parameters for the initiation of contain-ment isolation. Reactor coolant system p essure is sensed in addition to containment vessel pressure as parameters into the DB-1 safety features actuation system f or containment isolation.
The design of the isolation system is such that resetting of the isolation signals will not result in automatic reopening of the af fected valves. This requires deliberate individual operator action.
The results of the reconsideration of essential and non-essential systems is provided in Toledo Edison's response to item 4 of IE Bulletins 79-05 and 79-05A (TECo letter Serial No. 1-56, dated April 11, 1979).
The only modification identified is one for which a Facility Operating License amendment was previously requested in Toledo Edison letter Serial No. 487, dated March 23, 1979.
Based on the previous review, pending request and current containment isolation system input parameters, DB-1 is considered to have met the recommendation.
No further action is required.
Recommendation 2.1.5.a - Dedicated Penetrations for External Recombiners or Post-Accident Purge Systems (Task No. 13).
Response
This recommendation pertains to " plants using external recombiners or purge systems for post-accident combustible gas control of the containment atmosphere".
1210 346 This is not applicable to DB-1.
No further action is required.
Recommendation 2.1.5.b - Inerting BWR Containments
Response
DB-1 is a pressurized water reactor design; therefore, this recommendation is not applicable to this facility. No further action is required.
Recommendation 2.1.5.c - Capability to Install Hydrogen Recombiner at each Light Water Nuclear Power Plant.
(Task No. 14)
Response
No acti,n is required at the present time.
Recommendation 2.1.6.a - Integrity of Systems Outside Containment likely to Contain Radioactive Materials (Engineered Safety Systems and Auxiliary Systems) f or PWRs and BWRs (Task No. 15).
Response
A formalized leakage reduction program will be in place at DB-1 prior to restart af ter the planned March 1980 refueling outage. Dif ficulties are expected in gaseous system helium leak detection proposed by NRC staff. Alternative methods may be utilized pending further evaluation. Test results of the immediate leak reduction program will be availabic to the NRC within 30 days of their completion.
Recommendation 2.1.6.b - Design Review of Plant Shielding of Spaces for Post-Accident Operations (Task No. 16).
Response
DB-l's consulting architect engineer will be providing the design review. Due to current manpower availability, the results of the study are being scheduled for submit tal by April 30, 19 80.
Based on the conclusions of thic study, modifications may be recommended. An implementation schedule will accompany any proposed modifications.
Recommendation 2.1. 7.a - Automatic Initiation of the Auxiliary Ft adwater System for PWRs (Task No. 17).
Response
The DB-1 auxiliary feedwater system has a fully safety grade initiation system.
Toledo Edison complies with this recommendation. No further action is required.
1210 347 Recommendation 2.1.7.b - Auxiliary Feedwater (AFW) Flow Indication to Steam Generators for PWRs (Task No. 18).
Response
DB-1 has installed control grade AFW flow indicators as described in Toledo Edison's letter Serial No. 507, doced May 22, 1979. With these indications, DB-1 is con-sidered to comply with the January 1, 1980 control grade instrumentation recommenda-tion.
Toledo Edison will install one safety grade AFW flow indicator per fluid train.
Single f ailure criteria will be met utilizing presently existing safety grade steam generator level as acceptable back-up indication of flow. The safety grade AFW flow indicatora are projected to be installed prior to startup after the Spring 1981 efueling outage.
Recommendation 2.1.8.a - Improved Post-Accident Sampling Capability (Task Nos.
19 - 21).
Response
DB-1 will review appropriate techniques to assure the feasibility of promptly sampling and maalyzing reactor coolant and containment atmosphere under accident conditions.
These reviews will be completed and a report forwarded to you in June 1980 describing the review, results and description of any planned modifi-cations. A schedule for implementing any modifications will be provided at that time.
An interim procedure for taking highly radioact;ve samples will be developed.
This is currently projected to be completed in February, 1980.
Recommendation 2.1.8.t - Increased Range of Radiation Monitors (Task Nos. 22-24).
Response
Toledo Edison is investigating expanding ranges of the Davis-Besse radiation monitors.
Based on discussions with our consultants, an evaluation of state-of-the-art designs and availability of monitors will be completed in April 1980.
At that time, an implementation schedule of any proposed modifications will be provided.
Recommendation 2.1.8.c - Improved In-Plant Iodine Instrumentation (Task No.25)
Respons e Toledo Edison is investigating the capability and availability of improved in-plant lodine instrumentation.
An evaluation of state-of-the-art desi us is scheduled to be completed in April b
19 80.
A schedule of any proposed modifications will be provided au that t ime.
1210 348 Recommendation 2.1.9 - Analysis and Design of Of f-Normal Transients and Accidents.
(Task Nos. 26 - 29).
1.
Small Break LOCA analysis & preparation of emergency procedure guidelines.
2.
Implementation of small break LOCA emergency procedure guidelines.
3.
Analysis of inadequate core cooling and pre aration of emergency procedure guidelines.
4.
Implementation of emergency procedures and retraining related to inadequate core cooling.
5.
Analysis of accf lents and transients and preparation of emergency procedures guidelines.
6.
Implementation of emergency procedures and retraining related to accidents and transients.
7.
Analysis of LOFT small break test.
Response
1.
The analyses have been performed, emergency procedures guidelines prepared, procedures modified, and training provided.
No further action is required.
2.
Emergency procedures have been modified and operator training has been pro-vided. No further action is required.
3.
See tae response to recommendation 2.1.3.b.
4.
Emergency procedures will be modified and operator training provided based on the results of Item 3 above by March 30, 1980.
5.
Toledo Edison is participating in a combined B&W/EDS Nuclear /B&W Owners program to address this item. we believe this is an indepth and thorough program.
Due to the detailed nature of this effort, the generic results will be available as discussed in the B&W Owners Group meeting with the NRC staff on September 13, 1979, and documented in NRJ's meeting summary dated September 21, 19 79 (Log No. 4 35).
6.
Plant specific procedures and operator training based on the results of Item 5 above will be completed within 3 months of completion of Item 5.
7.
A generic B&W program will analyze the LOFT small break test.
As discussed with the staff by the B&W Owners Group in a September 13, 1979 meeting, the results of this analysis will not be available until Janorey 15, 1980. This is currently our most expedited schedule based on the workload of B&W personnel which we feel is consistent with its relative priority and capability of four staff to control the release of the detailed test results.
Recommendation 2.2.1.a - Shif t Supervisor's Responsibilities (Task No. 30)
Response
By January 1, 1980, management definition of the shif t supervisor's responsibilities will be reviewed.
Additionally, plant procedures shall be reviewed to ensure the staff supervisor's role is properly defined.
This will include a review of administrative, as well as, operational duties.
Any additional treining emphasis determined to be required as a result of this review shall be provided.
} { }4}
Recommendation 2.2.1.b - Shift Technical Advisor (Task No. 31).
Response
Toledo Edison 17 proposing a separation of the functions described in enclosure 2 of your September 13, 1979 letter.
The Shif t Technical Advisor (STA) will fulfill the function of accident assess-ment.
The specific details of how this individual is to administrative 1y function is presently dependent on manpower availability, further corporate direction and facility changes in progress.
As a minimum, a designated individaal will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day whenever nuclear safety systems are required to be operable beginning January 1,1980.
This designated individual will be in communi-cation with shif t operating personnel by telephone and/or radio at all times.
Station personnel will be required by procedure to notify the Shif t Technical Advisor in the event of:
1.
Any anticipated power transient 2.
Any reactor trip or load run backs 3.
Any loss of safety system function or offsite power supply The STA will be capable of reaching the control room within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of receiving a call and be in continuous communication with the control room while traveling to the station via vehicle radio contact.
The second function, operating experience assessment, will be provided by a non-shif t oriented review group within the Toledo Edison organization.
By January 1,1980, thi function will be provided and its administration documented in procedures.
By January 1,1981, the Shif t Technical Advisors will have completed training in the areas of reactor operations, as well as, transient and plant accident response. Additionally, a program will be implemented to expand the general technical education level of any Shif t Technical Advisor that does not have a dachelors Degree, or equivalent, in a scientific or engineering discipline.
Completion of this part of the program may not be a prerequisite for Shif t Technical Advisor based on the individuals prior experience and an evaluation of his capability by the Energy Supply Mission af Toledo Edison Company.
Recommendation 2.2.1.c - Shift and Relief Turnover Procedures. (Task No. 32)
Response
Toledo Edison is in the process of reviewing plant procedures for shif t and relief turnover.
Any revisions to these procedures will be consistent with this recommendation as clarified by the NRC staf f at the regional meetings. This revision is projected to be completed by January 1, 1980.
1210 350 Recommendation 2.2.2.a - Control Room Access (Task No. 33)
Response
Toledo Edison has taken steps to significantly restrict access to DB-1 control roon based on operational and administrative requirements.
Any additional effort required to comply with this recommendation will be implemented by January 1,1980.
Recomeendation 2.2.2.b - On-site Technical Support Center (Task No. 34)
Response
As a part of an ongoing review of plant response to emergenc.! ?s, Toledo Edison is reviewing the requirements of the onsite technical support center. By January 1,1980, an interim center will be established.
This center will be in close proximity to the control room, have plant reference documents easily available and will have a communication link to the control room. A permanent location for this center is currently under review an1 will be determined by the results of an overall evaluation of emergency plant response facilities. The results will be part of the review by the NRC Emergency Planning Team (EPT).
Final implementation will depend upon the results of Toledo Edison's evaluations and the EPT review.
ommendation 2.2.2.c - On-site Operational Support Center (Task No. 35)
- Response, The current on-site operational support center is being reviewed as a result of recent emergency drill evaluations.
By January 1,1980, the support center will be established as modified by these reviews.
Recommendation 2.2.3 - Revised Limiting Conditions for Operation of Nuclear Power Plants Based Upon Safety System Availability.(Task No. 36)
Response
No response is necessary as per Item a on page 1 of this attachment.
II.
Near Term Requirements ' for Improving Emergency Preparedness (Enclosure 7 of DOR letter of September 13, 1979)
Item 1 Upgrade licensee emergency plans to satisfy Regulatory Guide 1.101, with special attention to the development of uniform action level criteria b'ased on plant parameters.
(Task No. 54)
R$_sponse Toledo Edison is currently revising the DB-1 Emergency Plan to comply with USNRC Regulatory Guide 1.101.
The revised plan is to be available in time for the NRC Emergency Plan Review Team review of DB-1.
1210 351 Item 2 Assure the implementation of the related recommendations of the Lessons Learned Task Force involving instrumentation to follow the course of an accident and re-late the information provided by this ir.strumentation to the emergency plan action levels.
This will include instrumentation for post-accident sampling, high range radioactivity monitors, and improved in-plant radio-iodine instrumenta-tion.
The implementation of the Lessons Learned Taek Force's recommendations on int trumentation for detection of inadequate core cooling will also be factored into the emergency plan action level criteria. (Task No. 54)
Response
Instrumentation related to responses to I., Item f, recommendations 2.1. 3.b, 2.1.8.a, 2.1.8.b, 2.1.8.c will be f actored into the emergency plan action levels as appropriate. The implementation will be dependent upon the referenced responses.
Item 3 Determine that an emergency operations center for Federal, State and Local personnel has been established with suitable communications to the plant, and that upgrading of the facility in accordance with the Lessons Learned Task Force's recommendation for an inplant technical support center is underway. (Task No.56)
Response
An Emergency Operations Center currently exists to interface with Federal, State, and Local governmental organizations of f-site.
The adequacy of these facilities are to be reviewed with NRC Emergency Planning Review Team consistent with the NRC staff's schedule.
Item 4 Assure that Laproved licensee off-site monitoring capabilities (including additional thermoluminescent dos '_ meters or the equivalent) have been provided for all sites.
(Task No. 52)
Response
Toledo Edison will review the off-site monitoring capabilities with the NRC Emergency Planning Review Team consistent with the NRC staff's schedule.
Item 5 Assess the relationship of State / Local plans to the licensee's and Federal plans so as to assure the capability to take appropriate emergency actions. Assure that this capability will be extended to a distance of ten miles.
This item will be performed in conjunction with the Office of State Programs and the Office of Inspection and Enforcement. (Task No. 54) 1210 352
Response
Toledo Edison is working with the State of Ohio and local agencies in developing an ef fective and workable emergence plen.
The results of these efforts are to be reviewed by the NRC Emergency Plan Review Team consistent with the NRC staff's schedule.
Item 6 Require test exercises of approved emergency plans (Federal, State, Local and licensees), review plans for such exercises, and participate in a limited number of joint exercises. Test of licensee plans will be required to be conducted as soon as practical for all facilities and before reactor startup for new licensees.
Exercise of State plans will be performed in conjunction with the concurrence reviews of the Office of State Programs.
As a preliminary planning bases, assume that joint test exercises involving Federal, State, Local and licensee will be conducted at the rate of about ten per year, which would result in all sites being exercised once each five years.
Revised planning guidance may result from the on going rulemaking. (Task No. 54)
Response
Toledo Edison has had a joint interagency test exercise as recently as October 2, 1979.
Experience gained from tb4.s and previous exercises is being f actored into improvements in the DB-1 emergency plan.
It !.s Toledo Edison's policy to continue close cooperation in future exercise activities.
\\f\\