ML19318C430

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Forwards Addl Info Re Shift Manning,Licensing,Testing of Power Operated Relief Valve Isolation Sys,Automatic Trip of Reactor Coolant Pumps & Small Break LOCA Methods,In Response to NRC
ML19318C430
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 06/26/1980
From: Crouse R
TOLEDO EDISON CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
TASK-2.K.3.03, TASK-TM 624, TAC-43335, TAC-45334, NUDOCS 8007010464
Download: ML19318C430 (4)


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TOLEDO h EDISON Rcsaa P. Cncuse Docket No.

50-346 yet

"' S' 8 225 Licence No. NPF-3 Serial No. 624 June 26, 1980 Director of Nuclear Reactor Regulation Attention:

Mr. Darrell G. Eisenhut, Director Division of Licensing United States Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Eisenhut:

Your letter of May 7, 1980 to All Operating Reactor Licensees identified five items that your staff has determined are appropriate in light of the March 28, 1979 events at Three Mile Island - Unit 2.

The applica-bility of several items were modified by your letter of June 9, 1980.

Attached is Toledo Edison's response to these additional items as they relate to the Davis-Besse Nuclear Power Station Unit 1.

Very truly yours,

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THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 8 0 U 7 010%Y

TOLEDO EDISON DAVIC-BESSE NUCLEAR POWER STATION UNIT 1 RESPONSE TO ENCLOSURE 1 0F NRC LETTER OF MAY 7, 1980 I.A.I.3 - Shift Manning Your letter of May 7, 1980 identifies additional requirements will be provided in the future. Toledo Edison will provide an appropriate response af ter receipt and evaluation of the additional material.

I.A.3.1 - Revised Scope and Criteria for Licensing Examination Toledo Edison has reviewed the referenced document and believes that with the following minor exception the current reactor operator training meets the intent of the proposed requirements. The minor exception deals with how the operator training simulator is incorporated into the reactor operator's training program.

The Toledo Edicon Company training program for reactor operators includes simulator training at the Babcock & Wilcox (B&W) simulator. During this phase of the operator's training he is required to demonstrate capability to operate the Babcock & Wilcox reactor system safely in normal and emergency situations. The successful completion of this phase of training is currently a prerequisite to scheduling an examination by the NRC.

It is the position of Toledo Edison Company that the program we are using is adequate to assure competent and qualified reactor operators are employed. The generic deficiencies identified as a result of the TMI accident have been corrected by assigning Shift Technical Advisors on each shift and improving the B&W simulator software to accurately simu-late a small break loss of coolant accident with the break located on the pressurizer. Additional examination of operators by NRC at a simu-lator facility will not result in a significant improvement in plant safety.

I.C.5 - Procedure for Feedback of Operating Experience to Plant Staff Toledo Edison will insure that procedures are in place outlining feed-back of operating experience to plant staff by January 1, 1981.

II.K.3.1 - Installation and Testing of Automatic PORV Isolation System Subject to an acceptable evaluation of the influence on overall plant safety during plant transients and accidents Toledo Edison will automate the current PORV isolation system. This would be done in conjunction with returning the PORV and reactor protection system setpoints to values held pricr to alterations of IE Bulletin 79-05B. Appropriate preoperational testing will be provided. Given NRC concurrence of the setpoint modification a proposed design will be provided by July 1, 1981.

II.K.3.2 - PWR Vendor Report on PORV Failure Reduction By January 1, 1981 a report addressing this item will be submitted.

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. II.K.3.3 - Reporting Safety and Ralief Valve Failures and Challenges Toledo Edison will report challenges of reactor coolant system safety and relief valves in its monthly operating reports. This will be back-reported to commence April 1, 1980. Failures of such valves shall be reported pursuant to Section 6.9.1.7 of the " Davis-Besse Nuclear Power Station Unit 1, Technical Specifications, Appendix A".

II.K.3.5 - Automatic Trip of Reactor Coolant Pumps During LOCA Completion of the evaluation in this area is closely tied with tests being run at the LOFT Facility.

In particular, the Staff desires that test predictions be performed on L2-6 which is currently scheduled for December 1980. A meeting was held with industry representatives and the NRC Staff on May 22, 1980 to discuss the concern.

In consideration of the above, the January 1, 1981 date for evaluation completion does not appear to be achievable. Further interaction with the Staff appears to be necessary to resolve this issue. A revision of the NRC scheduled date is requested.

II.K.3.17 - Report on Outage of ECC Systems The complete review of system outages for the operational lifetime of the Davis-Besse facility is a considerable task that must be undertaken by knowledgeable personnel. The purpose of this exerted effort once expended is not clear. To undertake such an effort without visible benefit is not considered appropriate. Toledo Edison does not commit to providing this historic information.

II.K.3.30 - Revise Small Break LOCA Methods to Show Compliance with 10CFR 50 Appendix K Your letter of May 7, 1980 identified clarifying information would follow. The currently used small break ECCS evaluation model has previ-ously been reviewed and approved by the Staff and conforms to the requirements of 10CFR 50, Appendix K.

The Staff has not identified any specific areas where changes are necessary to existing model. As a result, no commitment is provided pending further clarification.

II.K.3.31 - Plant Specific Calculations to Show Compliance with 10CFR 50.46 Your letter of May 7, 1980 identified clarifying information would follow. Specific deficiencies and revisions need to be identified prior to modifying existing models. Therefore, no commitment is provided pending further clarification.

III.D.3.4 - Control Room Habitability The Davis-Besse Nuclear Power Station Unit 1 (DB-1) was reviewed during its operating license stage review (Final Safety Analysis Report, Sec-tion 9.4) for both radiological and toxic gas protection for control room personnel. The acceptable conformance with General Design Criteria

. 19 is documented in NUREG 0136 and its Supplement No. 1, " Safety Evalua-tion Report Related to the Operation of Davis-Besse Nuclear Power Station Unit 1".

This is considered an appropriate' review for the requested information. Based on the earlier review the current control room habitability' systems at DB-1 need not be modified.

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